Ukrainian decision for construction K3,4 in breach with Espoo and Aarhus

Today, in a haste that would be more appropriate in a different kind of situations, the Verkhovna Rada adopted the Law on the construction of two new power units at the Khmelnitsky nuclear power plant. Our Deputies were neither disturbed by substantial violations that were committed in the course of the bill drafting, nor by actual aggravation of energy dependence on Russia by adding nuclear power dependence to the natural gas one.

The Ukrainian apologies for politicians are little worried about the fact that having passed that decision they violated laws. For example, the bill on the construction of new power units does not contain the State Environmental Expert Review required by the Law of Ukraine “On making decisions on the location, design and the construction of nuclear installations and facilities …”. Neither it has a feasibility study, which is also requires under that law. In other words, we are expected to believe the nuclear sector representatives’ bare word that construction of the two units is safe and will pay off some day. The Energoatom ex-President Yu.Nedashkovsky estimated the payback period to be 25 years. Even if you believe this very dubious figure, which does not take into account the unit decommissioning, spent nuclear fuel and nuclear waste management, the project can hardly be called highly profitable.

The report on informing neighbouring countries about possible transboundary impact of the project, included in the bill, contains, for example, a polite letter from the Austrian Government, dated August 27, 2011. The letter contains a reminder that Austria, as long as as in on March 10, 2011, requested additional materials on the Khmelnitsky NPP power units 3 and 4 for examination, but never received any. To put it mildly, it is difficult to call it ‘consultations with affected countries’.

Nevertheless, the Deputies did not stop at ignoring laws. Just like the nuclear sector people, they can hardly be suspected of respect for Ukrainian citizens and their rights. Several local councils in communities within the 30-km zone did not agree to the new power units being placed next door to them. Obviously, the “national significance” status does not imply any consideration of the interests of some ordinary citizens out there. Otherwise how do you explain the direct falsification of public hearings results in the village of Kopytkiv in Rivne Oblast and the absence of any attention to the local councils’ negative decisions?

Those are the most significant direct violations of Ukrainian legislation committed in preparation of construction of power units 3 and 4 at the Khmelnitsky NPP. Now, some details about safety.

Our nuclear power sector is the thriftiest in the world! Otherwise it is difficult to explain their indomitable desire to build the two blocks on the foundation that was laid a quarter of a century ago – and was not even protected. In a similar situation, Bulgarians obviously didn’t have enough “effective managers”, that is why they thought about the people and demolished the foundations. With just a little difference – unlike in Ukraine, structures there were protected. Then, from bad to worse. Those foundations had been designed for other types of reactors and they do not make it possible to include in the current engineering design one of the most important elements of the unit passive safety system – the corium trap. Let me remind the reader that it is shortcomings in the passive safety systems that caused  the Fukushima accident. The State Nuclear Regulatory Inspectorate (SNRI) never gave the all-clear for use of the existing structures. I wish to hope that that the SNRI will continue to maintain its principled stand and Olena Mykolaychuk will not be dismissed.

Another touch to the description of safety at the existing and planned nuclear power units in Ukraine. None of them is designed to withstand a crash of modern airliner. Publicly available documents explain dismissal of the possibility of such an accident by its low probability and by air defence. It is hard to believe that the Pentagon was protected any worse, but an aircraft did fall on it!

Now, about geopolitics. Using the Russian loan money, Energoatom plans to build the Russian nuclear power units that can run exclusively on Russian fuel. Note: that decision is explained by the need to achieve energy independence. Is it a kind of a sick joke or have the people of Ukraine been conned again? Some more bitterness. Terms and conditions of the Russian loan is still unknown, but it will definitely be provided against the collateral in the form of our taxes.

This is the ugly picture that the hastily adopted Law created. People who drafted it were obviously aware of all his flaws, that is why they tried to push it through in the hectic last days of work by the Rada’s current convocation. Therefore, we will have to do everything possible to make the new parliament, fair and democratic, to revoke that Law.


33014, Rivne, Stepana Bandery str. 41, office 95