Plans on building nuclear blocks #3, 4 of Khmelnytsky NPP are based on erroneouse forecast, and negative environmenatal impacts are simply ignored – Ecoclub Rivne is an environmental NGO

Plans on building nuclear blocks #3, 4 of Khmelnytsky NPP are based on erroneouse forecast, and negative environmenatal impacts are simply ignored



In 25 years after Chernobyl and in 2 month after Fukusima accidents nuclear operators place next project ofnuclear blocks № 3, 4 buildingon Khmelnytsky NPP for public consideration. There is a set of various problems arose from the project of construction KhNPP 3, 4 that make it very doubtful.

The Law of Ukraine on Urban Developmentand governing/management№ 3038-IV was adopted onFebruary 17, 2011. It has changed the procedure concerning how a building project could be assessed (expertise) by the Law in Ukraine concerning Nuclear Energy Use and Radiation Safety. This is now regulated by a new Law (Article 31). According to paragraph 5 of article 31 of the Law from June 12, 2011,: “determination of cases and procedures of building project assessment (expertise)by other Laws is not allowed”. All this significantly eliminates the role of the independent state nuclear regulator known as the State nuclear regulation inspection of Ukraine –(SNRI), which has been denied its obligation to take its conclusions into account during the state environmental expertise of the project of construction KhNPP 3, 4. Therefore it is unclear why the National Nuclear Energy Generating Company ENERGOATOM (NNEGC ENERGOATOM) is still officially planning to carry out the state environmental expertise of the construction of these new blocks construction.

New Law also restricts opportunities for public participation in decision making process related to the construction of new KhNPP blocks. According to Article 21, only projects of urban architectural documentation at local level developed in accordance with established procedure can be considered on public hearings. It deprives the right of public participation in decision making in environmental matters during building certain dangerous objects.

In order to understand why the changes of Ukrainian legislation have been done it is worth quoting the Decision of the State nuclear regulation inspection Board № 24, November 12,  2009 “About the results of the state nuclear and radiation safety assessment  of the reporting documents on the technical  conditions and inspection of block № 3 at Khmelnitsky NPP”. The following is mentioned:

  1. The inspections were held  from 15.04.2006 till 29.12.2006, therefore during this time the possibility of an existing building construction use was considered only for the project started in 1985, i.e. VVER-1000/V-320.
  2. The analysis of the possibility of the existing energy block № 3 during KhNPP construction and the reactor type VVER-1000/V-320is missed in the Reporting Documents.
  3.    The inspection was incomplete, namely
    • major number of premises located below zero level were as they had been flooded
    • Built up details of bending down reinforcing ropes and channeling were significantly damaged during the fire in 1989, these  were not inspected
  4. Executive documentation concerning reinforced-concrete (about 30% missed) and metal (about 12% missed) used for construction of energy block № 3 is missing.
  5. Service life of existing constructions of energy block № 3 KhNPP is determined according to the results of inspection, there has been no consideration of remarks mentioned above, and the operating lifeis not sufficiently justified even for a building of this energy block with a reactor type VVER-1000/V-320.

 “All this mean that ENERGOATOM couldn’t prove the technical capacity of using an existing construction for building the new blocks. That is why the nuclear operator has just obtained changes in the Law and has confirmed it is not necessary for bases constructed in the last century to be listed as safe.” –Andriy Martynyuk, Chair of the Board of Rivne NGO “Ecoclub”, comments. “It seems that justification of the possibility to integrate existing constructions into the project NPP with VVER-1000/V-320b that had beenincluded in the Schedule of preparation and building energy blocks № 3, 4 on KhNPP on request off the SNRIU has not been done yet. It is not placed into Informational analytic review of materials, “Khmelnitsky NPP. Feasibility Study of building energy blocks № 3, 4. 

Nuclear operators have not published a Feasibility Study (FS) concerning building blocks on KhNPP yet. FS of the project is a document demonstrating that the project is economically reasonable, technically possible and safe. Regarding the situation at Khmelnitsky NPP’s, the official answer is as follows: “according to the law only materials of the Environmental impact assessment (EIA) as a part of FS could be a subject for public discussion.”

“A Feasibility Study as a basic document describing economic, energy and nature protection value of the project realization has not been announced yet. Instead of a FS, an Informational analytic review of materials (IAR) is palmed off to us. It is as different from a FS as an Alphabet differs from The Big Soviet Encyclopedia.” – Martynyuk says.  “It is not clear from IAR how the system of passive heat removing and the trap for molted fuel will be realized. Namely these safety elements of the reactor distinguish VVER-392b how the plant will be build VVER-320 for which bases have been already constructed. Therefore we have a question how to use these key elements to project how the safety system of blocks will be built.”»

Environmental impact assessment in Ukraine is developed on the basis of the State building rules А.2.2-1-2003 “Design. Structure and content of Environmental impact assessment (EIA) materials when designing and building of enterprises, houses and constructions”. The document includes a clear requirement regarding comprehensive assessment of all negative impacts of the project realization, and is also a requirement to analyze alternative project options. The main negative impacts related to building of nuclear blocks are nuclear waste management and radioactive wastes during thousands of years, as well as termination of block operation. All these elements of negative environmental impact are not considered in promulgated IAR and in EIA project.


 “For some reasons ENERGOATOM thinks that a decision of the Government regarding nuclear industry development cancels requirements of the State building rules regarding assessment of all  negative factors without any exception appear as a result of building new blocks. Construction and operation of a nuclear block is the “cleanest” link of a long chain of industrial objects that is necessary for a block functioning. The dirtiest links are nuclear and radioactive waste management. Last one a thousand times more radioactive then fresh fuel and can be used as raw materials for production of a nuclear bomb. All these negative aspects of the building project are completely ignored by the EIA. There is no country in the World which has a decision regarding nuclear and radioactive wastes. The USA spent years and billions of dollars for preparation and an investigation into the Yucca Mountains’ disposal. After that there was not one expert who agreed to sign a Guarantee of safety of the disposal of nuclear waste. Obviously ENERGOATOM has a secret extraordinarily cheap technology of nuclear and radioactive wastes management during thousands of years.” – Andriy Martynyuk wonders.

“As mentioned in the announced materials the project on termination of operation will be developed during the blocks’ service life. However it is unclear how the cost for terminating the blocks operation can be included into the FS. It is equal to fly plane up and think that a decision about a landing site will be taken during the flight” – continues Martynyuk.

The Informational analytic review presents a price for the blocks construction that is a bit more than 25 billion UAH without VAT.  At that this price the following expenses are not included: costs for the termination  the blocks operation, costs of nuclear waste management, costs of radioactive wastes management, and costs of radioactive materials transportation.

If all listed expenses is included into the cost of the project it will be considerably oversized compared to the present one. Secondly as a practice shows, the price of block construction is increasing during its building. So even in April 2010 ENERGOATOP estimated the price of construction at 15 billion UAH and now it is already 25 billion UAH without VAT. Besides 85 % of the construction will be funded by Russian credit money.

“For me, it is not clear how economic suitability of the project can be estimated when most of the expenses are not included into the project; it is extremely difficult to count them. However 25 billion UAH looks very serious.  Let’s say, this money can be used for reconstruction of all housing facilities of one oblast of Ukraine within an average territory and to install cogeneration units instead of old soviet boilers. As a result natural gas consumption will be reduced, people’s well-being will increase, and more jobs will be created rather than when blocks are being constructed. “– says Andriy.

An IAR planning of nuclear industry activity until 2065 is based on the Energy Strategy of Ukraine till 2030 which was adopted in 2006. However even for the past 5 years the moment the Strategy was adopted it became clear for all that it was incorrect.  In 2011 a real state of Ukrainian energy differs from the one planned many times.

“It is also not clear how active a big national company can be based on a wrong document.  The Energy Strategy was adopted by the President Mr. Yushchenko V., who governed at a time during the slogan of energy independence. It is difficult to understand how energy independence can be achieved while using Russian credit for building of Russian type blocks when one of the conditions of the credit is to buy Russian nuclear fuel not only during the blocks service life but during the projects life time of operation. Instead of achievement of energy independence it is only increased. Now the creditor can use not only prices for gas but also prices for nuclear fuel to achieve its aims. Maybe its next desire will be to establish one more military base on the territory of our country. Ukraine entering into a Customs Union can only be hypothesized at the moment.  So construction HkNPP 3, 4 is a strategically risky, economically unprofitable and an environmentally extremely dangerous idea. ”- Andriy Martynyuk summarized.

NGO «Еcoclub»