In November 2010 the EBRD and the European Union's Euratom announced plans to finance what is called by Ukraine a safety upgrade project, but what is in fact a precondition for the lifetime extension of the reactors. European public money would therefore be used to expand the lifetime of Soviet-era nuclear reactors instead of investing in safe closure and decommissioning - costs which haven't been accounted for yet in Ukraine's plans.
An expert review of Ukraine's Nuclear Power Plant Safety Upgrade Program, that is to be financed by Euratom and the European Bank for Reconstruction and Development (EBRD), shows that some of the measures included in the SUP are necessary for the lifetime expansion of the plants and not for their regular functioning until the initially planned term.
According to the ecological assessment (EA) report released in October 2011, the safety upgrade project (SUP) program costs around 1.34 billion euro, though EBRD estimates are upwards of 1.45 billion. The European Bank for Reconstruction and Development intends to grant up to 300 million euro (US$ 400m) for the project, and 500 million euro (US$ 665m) is to be provided by the Euratom loan facility. Currently both institutions are preparing loans and the EBRD’s Board of Directors is scheduled to decide on this loan on 18 September, 2012 and Euratom in May 2012.
The EBRD and EC have requested a strategic environmental assessment (SEA) for the SUP. However as early as the project’s scoping stage, the public was informed that EBRD staff and Energoatom agreed only to an ecological assessment (EA) for the project in line with procedures outlined in European SEA Directive 2001/42/EC regarding public participation.
SUP includes measures for the safe modernisation of all of Ukraine’s 15 operating nuclear reactors and should be implemented by 2017. Twelve of these reactors were designed to finish operations before 2020, and two units were supposed to be taken off the grid in 2010 and 2011 but received licenses to operate for additional 20 years. The SUP is therefore designed for nuclear reactors that face the end of their designed lifetime.
In 2005 Ukrainian nuclear power plants provided about 50 percent of the electricity produced in the country. According to Ukrainian energy strategy, this proportion of nuclear power should remain until 2030. This decision is justified by the presence of domestic uranium deposits, the stable operation of existing nuclear power plants and the high costs of constructing new nuclear power plants.
According to the Energy Strategy, by 2030 seven units will have received a license for a lifetime extension of 15 years, including Zaporizhia 3-6, Rivne 3, Khmelnitsky 1, South Ukrainian 3 and two units that started operation in 2004: the Khmelnitsky 2 and Rivne 4. In 2004 the Ukrainian Cabinet of Ministers approved the “nuclear reactors lifetime extension plan”, which foresees extending the lifetime of all operating nuclear reactors by an additional 15 years.
Prolonging the operation of the nuclear power plants from 30 to 45 years requires a huge effort in terms of modernisation and safety improvements in order to reach internationally-acceptable status. The EA SUP however concerns only the safety improvements, and this is only one side of the development. The other side is the material degradation of reactor components of which the most important is the reactor pressure vessel (RPV). The RPV is the only component which cannot be replaced. Due to harsh conditions in the primary system (high temperature and pressure and high neutron flux), embrittlement, corrosion, cracks and abrasion weaken the primary cooling system material. A failure of primary system components could lead to a loss of coolant accident.
To prevent the development of a severe nuclear accident, so-called accident management measures are implemented. The SUP mentions such measures as guidelines for organisational activities and emergency measures.
Another important influence is from the European Union nuclear power plants “stress test” that Ukraine has agreed to participate. In its report the Ukrainian nuclear authority has already defined some measures that are to be completely implemented at the nuclear reactors, if the operators wish to apply for lifetime extension. The peer-reviewed results will not be known until May 2012 and may offer new insights and subsequently new safety measures to be required at the Ukrainian nuclear power plants.
In fact, Euratom and the EBRD have been asked to finance a program labelled only as ‘safety upgrades’, though it is impossible to argue this both technically and economically.
SUP precondition for lifetime extension
Proponent of the SUP, the Ukrainian state nuclear operator NEC Energoatom claims that SUP measures will address only safety measures and are not a precondition for the lifetime extension of reactors. However a new report shows this claim is misleading: SUP measures will be used to provide a sufficient safety level to extend operations and are not necessary for safely shutting down the reactors.
While the Ecological Assessment (EA) for the safety upgrade project claims that the planned safety upgrade measures are not part of extending reactor lifetime beyond their designed 30-year lifetime, this study shows that the safety measures for 15 reactors are in fact connected to the lifetime extension program. SUP measures like those related to component integrity are conditions for extending the lifetime of reactors. The reasons for this are as follows:
- Measures to address only safety issues and not lifetime extension simply do not exist. The EA SUP explains that “security systems and other essential safety equipment are kept operating until the final stop and first phase of the decommissioning, i.e. until the unloading of the spent nuclear fuel.” The dates on which Ukraine’s reactors reach the end of their design lifetime are indicative of the need of reactor’s life-time extension one unit in 2012, two in 2014, two in 2015, two in 2016, two in 2017 and two in 2019.
- Economic viability - both loans need to be repaid, and Euratom cannot grant loans without a statement from the European Investment Bank (EIB) showing that the loans can be repaid, likely to be based on the future operation of those nuclear power plants.
Officially these European institutions have been asked to finance the programs labelled as safety upgrades, though it is impossible to argue this technically or economically. This claim seems to have been chosen because:
- EBRD and Euratom financing conditions allow only for safety upgrade financing so the lifetime extension needs to be concealed;
- this avoid a discussion about ageing problems of Soviet-era nuclear power plants once the lifetime extension plans for all 15 reactors by 15 years would become known
- this avoids conducting an strategic environmental assessment (SEA); the SUP is not only called a safety upgrade program but also substitute sectoral policy by intending to modernise and prolong a whole nuclear power-producing sector; even pilot projects were run. A full SEA would require assessment of alternatives to reactors life-extension and transboundary involvement.
This report finds that no information about the SUP was provided outside of Ukraine, and it is probable that neighbouring states would demand full transboundary SEA and EIA (Environmental Impact Assessment) for such a sensitive topic.
Instead only the EA designed solely for the SUP was conducted in Ukraine without any transboundary assessment. The report shows that this approach is far from best practice in the nuclear field and does not comply with international conventions like the ESPOO convention on transboundary impact assessments or the Aarhus Convention on access to environmental information, nor does it even come close to fulfilling EU legislation. The EU’s SEA directive would have to be applied to assess alternatives to safety upgrades and lifetime extension; instead the EA concludes that there are no alternatives to safety upgrades and claims those measures are needed even for safe closure.
We expect Euratom, the European Commission and EBRD to follow their guidelines and to enforce good governance, public participation and information disclosure and good practice with respect to international conventions like the strategic environmental assessment protocol, Espoo and Aarhus.
More broadly nuclear energy today is causing even more concern than before the nuclear accident at Fukushima. European institutions should encourage project applicants to inform the public about their projects in line with all available tools like Espoo contact points. It is unacceptable that a major, high-risk project is being considered for financing from European institutions without the public in EU member states being informed.
One year after the Fukushima accident, the European public would welcome information about the lifetime extension of nuclear power plants that are already three decades old.
The SUP was prepared prior to the nuclear disaster at Fukushima, and it is not acceptable that decisions on the program are taken before the stress tests are completed and the EU draws its first conclusions about reactor safety. We believe that these institutions will not finance Ukrainian reactor safety measures before the peer review of Ukraine’s stress test report has been prepared.
The EBRD and Euratom want to hide the fact that they are contributing both financially and politically to at least another 15 years of nuclear risk. The argument that Ukraine would go ahead and operate the reactors even without EBRD and EURATOM funding is troubling and implicitly alleges that the Ukrainian operator and regulator would act irresponsibly.
The Ukrainian authorities already licensed lifetime extensions at Rivne reactors 1 and 2 without first applying the Espoo Convention. The Espoo implementation committee is now inquiring about violations in this case. We expect both Euratom and the EBRD to withhold a decision about SUP pending a resolution to the Rivne 1 and 2 lifetime extension decision.
Some modernisation measures are “significant changes” e.g. the planned nuclear fuel exchange and call for EIA implementation. One of the first SUP objectives is the introduction of second generation fuel with improved cycles in order to reduce neutron fluence on the reactor vessel to mitigate embrittlement effects. The switch to longer fuel cycles is not mentioned in the SUP but is an objective of the energy strategy. High fuel burn-up increases the risk of accidents, because it accelerates the accident progression.
The reliability of the Ukrainian nuclear safety programs are cause for concern. A 2006 EBRD press statement says “…a modernisation programme for all nuclear power plants in Ukraine currently being implemented will upgrade all 13 nuclear reactors to internationally recognised nuclear safety level by 2010.“ Thus the question of why are new programs, including the SUP within the „Comprehensive Safety Upgrade Program,” necessary? This study provides an overview of the very non-transparent management of safety improvement programs in Ukraine. It seems that all safety measures not implemented by 2010 were merely incorporated into the SUP for the period 2010 to 2017.
Source: 'Critical Review of the “Ukraine NPP Safety Upgrade Program” - Why the European Bank for Reconstruction and Development and EURATOM should not finance the lifetime extension program of Ukrainian nuclear power plants'; March 2012 by Antonia Wenisch & Patricia Lorenz; Commissioned by CEE Bankwatch Network. Available at: http://bankwatch.org/sites/default/files/Ukraine-SUP-review.pdf
Contact: David Hoffman, Na Rozcesti 1434/6, 190 00 Praha 9 – Liben, Czech Republic
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