An open letter to Ukrainian MPs concerning parliamentary hearings on the closure of the Chernobyl AES
On 5 December 2000 the parliamentary hearings on the closure of the Chernobyl atomic electric station (ChAES) was held, and on 15 December the station was ordered to be closed. On this day you must recollect what was the Chernobyl catastrophe for the entire planet and especially for us living in the vicinity of Chernobyl. Recollect that the reason of the catastrophe was a chain of slight and grave violations of the operating laws, as well as the violation of instructions, norms and standards. Try to understand whether it is possible to violate the safety rules in the atomic power engineering, in particular when atomic stations are widened, as in the case of Khmelnitsky and Rivno stations.
If you share, partially or entirely, the ideas of this appeal, please support us by sending your considerations to the Supreme Rada of Ukraine by the address: To I. S. Pliushch, the Head of the Supreme Rada of Ukraine, 5 Grushevskiy St., Kyiv-19, 01019; fax (044) 293-1001.
Thanks you in advance.
Sergiy Fedorynchyk, the head of the information center of the Ukrainian ecological association Zeleny svit
An open letter to Ukrainian MPs concerning parliamentary hearings on the closure of the Chernobyl AES
To Prime-Minister of Ukraine Viktor Yushchenko
To first vice-Prime-Minister Yuri Ekhanurov
To vice-Prime-Minister Yulia Timoshenko
To Head of the Presidents administration Volodymir Litvin
To Secretary of the Council on National Security Evgen Marchuk
To Minister of power engineering Sergiy Ermilov
To Minister of ecology and natural resources Ivan Zayets
To head of the administration of nuclear regulation Oleksandr Smyshliayev
To General Prosecutor of Ukraine Mykhaylo Potebenko
A Copy: To the President of European Bank of Reconstruction
and Development Jean Lemiere
ON THE CLOSURE OF ChAES, WIDENING OF KHMELNITSKY AND RIVNE ATOMIC STATIONS AND ENERGY PRODUCING POLICY OF UKRAINE FROM THE VIEWPOINT OF SAFETY
Respected peoples deputies!
Lately we happen to hear the opinions of some MPs concerning the opportunity of shifting the term of the closure of the ChAES. These opinions cause an extreme worry if the Ukrainian and international public. Any speeches and actions concerning the atomic energy production must be regarded firstly from the viewpoint of safety. The safety of the atomic power production must be a top priority goal and internal need that will force everyone to self-control all the works concerning this safety. This means that we must strictly obey the law On the application of nuclear energy and radioactive safety, as well as all norms, regulations and standards. The State administration of nuclear control in Ukraine (SANCU) determined the date of the closure of the ChAES no by a rule of the thumb, but taking consideration of the existing norms of safe AES operation and the corresponding computations. The ChAES has practically exhausted its resource. Letter No. 73-03/0871-7C of SANCU reads that the main technical constraint as to the exploitation lifetime of the energy block No. 3 of the ChAES is exhausting the gap between the technology channels and the graphite layer… The term cannot be prolonged. That is why any negotiations about the postponement of the closure may be carried out only having the document in writing, which must be based on the norms and computations presented by professionals in charge. People, who chatter on this topic without the proper basis, act in the extremely irresponsible manner, regardless of their motives.
The date of 15 December for the closure of the ChAES was named before the international community by the Ukrainian President himself. Even mere talks about shifting this date by state officers cause a great damage to the international reputation of Ukraine. All the world community and the Ukrainian people have awaited this day for 14 years. The closure of the ChAES will be, as a popular song sounds, a great victory causing tears.
In this connection Ukraine expects, with understandable reasons, the international financial aid. Yet, there is no reason to use this aid for building of blocks No. 2 of Khmelnitsky AES and No. 4 of Rivne AES (Kh2/R4 in what follows). It is possible that the international aid will be needed for the closure of these blocks as well. After a thorough analysis of the documents concerning the state of power engineering, project documents, legal acts, exchange of letters with state organs concerning the projects Kh2/R4, one is obliged to conclude: AT THE GIVEN MOMENT BUILDING ADDITION BLOCKS Kh2/R4, FROM THE POINT OF VIEW OF SAFETY, IS AN ECOLOGICAL, ECONOMIC AND LEGAL ADVENTURISM!
Up to now we have no positive conclusions of the ecological expertise of estimation of the influence on the environment, that would guarantee admissibility of the project, and no technical and economical confirmation (TEC) of these projects, made keeping the demands of the Ukrainian legislation. According to the law On investment, financing of construction under such conditions contradicts the law. Nonetheless, these activities are done owing to the passivity of prosecutors office.
V. Shcherbytsky was the one who wrote in his secret letter to the Central Committee of the CPSU about the dangerous geological conditions on the site of Rivne AES (deep tectonic breaks and karstic caves in the ground). In this letter he also informed about serious emergencies in the first block of the ChAES on 9 September 1982 and 25 February 1983, as well as about accidents in the work of 2nd and 3rd blocks. It the reaction in Moscow were correct, there might be no catastrophe at the 4th block in 1986!
The site of Khmelnitsky AES has not sufficient quantity of water for cooling two blocks -- that was a conclusion of independent ecological expertise headed by academician D. M. Grodzynsky. What is then the basis of the National Energy Program of Ukraine till 2010 (NEPU-2010), which suggests the widening of the KhAES up to four blocks?
Such a contradiction to the common sense has appeared because the Supreme Rada adopted this Program (on 15 May 1996), violating Article 9.2.3 of the Regulations of the Supreme Rada of Ukraine. Concretely, the discussion of the NEPU-2010 was abridged, no decision was taken about the additional scientific, economic, financial and legal expertise of the draft of this Program or about its public discussion. Article 9.2.4 item 2 of the Regulations of the Supreme Rada was also violated: the approved Program and the report on its fulfillment have never been published in the proper sources, Golos Ukrainy or other official editions. The NEPU-2010 is made inaccessible at all for the Ukrainian public: it is classified as For service use only, although such category of secrecy is not stipulated in the Ukrainian legislation. In spite of the repeated requests to the Ministry of power engineering, Ministry of economics, Cabinet of Ministers and corresponding committee of the Supreme Rada we have not managed to clarify who namely, in which state body and on the vase of which legal document made the NEPU-2010 secret.
The decision about the widening of Kh2/R4 may be taken only on the base of the well-grounded proof of its economic expediency. This must be done in the framework of the TEC prepared according to the conventional procedure. The TEC for the first stage of the KhAES exists prepared in 1974, and TEC for the second stage of RAES prepared in 1982. Since that time all political, economic and juridical conditions have changed, and all the changes result in the essential increase of the worth of electric energy produced by an AES. There exists no calculations of the cost of closing Kh2/R4 and long term (for thousands years!) storage of radioactive waste. Shall we have enough profits to recompense these expenditures? The experience of the ChAES has demonstrated that the closure of an AES may be more costly than its building. The Ministry of economics of Ukraine tried to keep away from the problem, it did not consider and approve the above-mentioned TECs. These TECs are not only archaic, but also illegal, since they do not satisfy the Demands of the State Constructive Norms (ДБН A.2.2-3-97) and the law On the application of nuclear energy and radioactive safety. In particular, a number of rules listed in Article 37 of this law concerning the procedure of taking decision about the allocation of nuclear objects were broken. The projects Kh2/R4 are also doubtful from purely technological considerations. These energy-producing blocks can operate in the mode of providing the basic load, but not the peak one. On introducing one million kW of basic load it is necessary to introduce two million kW for maneuver load. So Kh2/R4 needs the additional four million kW for maneuver, and the production of this power is not planned. Specialists confess that after the introduction of energy blocks Kh2/R4 the work of the energy-producing system of Ukraine will become less stable!
According to the technological regulations, when the frequency falls below 49.0 Hz (and this may occur after emergency switching out of even one atomic block), almost all blocks of an AES would automatically unload by 10% from their nominal power that causes the chain reaction, and in five minutes all the blocks of the AES would completely switch off the energy system, which would result in catastrophic consequences within and without the country. This threat is confirmed by actual facts. On 4 February 2000 at 4:04 p.m., as a consequence of switching off the 2nd block of Zaporozhye AES the first automatic guard level acted, and the frequency of the electric current in the system diminished to 49.1 – 49.2 Hz. This automatically resulted in the fall of the power of 1000 MW because of the emergency switch-off of the 1st block of South-Ukrainian AES, which, in its turn, resulted in the diminishing of productivity of other blocks of the AES by 10%. The increase of the frequency from 49.0 to 49.4 Hz was carried out during next 4 minutes 39 seconds by way of switching off of the provision centers throughout the country. Thus, the collapse of the national energy system had to occur in 21 second, and the main reasons were the technical peculiarities of atomic energy producing blocks! Abolishing moratorium on the building of atomic energy blocks in 1993 the Supreme Rada did not act according to the legal procedure. The fact that no legal justification of this decision has not appeared during 7 years after the abolishing the moratorium, testifies that the decision of the Supreme Rada made to meet the request of the government was erroneous. The composition of the government since than has changed five times, but the neglect of safety never changed. The current government has to act in another way! Unfortunately, Ukrainian mass media neglect safety rules as well, executing orders of the proper elucidation of the Ukrainian energy producing policy, without any analysis of the real reasons of the crisis phenomena. This superficial manner resulted in the ban of critical materials about the problems of atomic power engineering, although the problems were growing all the time. All energy production blocks of Ukrainian AESs, without any exceptions, have no permanent licenses for exploitation, while the operation according to temporary permissions is forbidden by the Ukrainian legislation and international agreements. If to be unbiased, one should stress the question in a quite different way, when elucidating problems of energy production. There is no crisis of energy producing potential in Ukraine, what exists is crisis of payments caused by inability (and sometimes unwillingness) of the customers to pay for energy. The total potential in Ukraine in 54 million kW; at peak hours the demand reaches only 28 million, while at the rest of the time it is even less. The supercilious potential is not normally demanded. Specialists assert that if to organize the energy market properly, then Ukraine, using the existing potential, could meet all her needs, and even sell some energy abroad, thus accumulating finances for the modernization of existing facilities. The present government has already made some useful steps in this direction. Diminishing pay arrears to the AES workers is very important, since such arrears are incompatible with safety. It is clear that certain persons and structures, which get profit from the existing disorder at the energy market, are interested in regaining the status quo. They frantically attack the government under each pretext and use any kind of arguments. To this end they try to shift the term of closure of the ChAES; besides, they attempt to relate the obtained international financial assistance with the necessity to widen Kh2/R4. These negotiations serve for the destabilization of the situation in Ukraine, in Western countries they can be understood as blackmail and intimidation, and this does not encourage leading the country out of the critical situation. The government has a duty soberly, accounting for safety, observing laws, economic expediency, ecological permissibility and public opinion to reconsider the dangerous situation with the projects Kh2/R4. It is the Supreme Rada that can most successfully create favorable conditions for such reconsideration, accounting for long-term interests of the society, instead of fanning the fire of hysteria and speculations of the circles that favor the crisis in the power engineering. In the question of recompensing the closed ChAES it would be instructive to remark on inconsequent and incorrect activities of the West. As President L. Kuchma wrote to British Prime-Minister T. Blaire in April 1998, the widening of Kh2/R4 was suggested by Western partners as an alternative to the Ukrainian proposition to build the vapor-gas electric station. It was the countries of the Big Seven that suggested to include this variant to the Memorandum on mutual understanding in 1995, although the Ukrainian proposition was the best to solve the problem of maneuver potentials for peak loads of the energy system.
It goes without saying that the most profit from the widening of Kh2/R4 will be received by the nuclear companies of France, Germany and the USA, which have already concluded preliminary contracts for getting credits that in the final count will be given to Ukraine. In this way the money extracted from Ukrainian taxpayers and customers will, through these credits, enrich Western companies, which are loosing the market because of the decrease of demand of the atomic energy in the West. The European Bank of reconstruction and development, declaring its devotion to observing national and international laws, actually intends to credit Kh2/R4 on the basis of the doubtful document, which have no legal leg to stand upon in Ukraine. Thus, the report on the estimation of the influence on the environment, written by the British firm Mowshell consulting, skipped all acute problems, does not meet the demands of the Ukrainian legislation, in particular of the State Constructive Norms (1995), and was not approved by the Ministry of ecological resources of Ukraine. And the American firm Stone and Webster wrote: The proof of the economic expediency of widening Kh2/R4 uses a number of fantastic arguments. This work was sharply criticized by international experts, it does not obey to the State Constructive Norms of 1997 (concerning the demands to the TEC of investments) and was not approved by the Ministry of economics of Ukraine. This year the firm Stone and Webster went bankrupt, since they could not fulfil the contract on closing an AES in the USA. Such international intermediaries do not carry any responsibility for their conclusions!
Criticizing the project of widening MKh2/R4 and realizing the complexity of the situation in Ukraine, public organizations have their own convictions about the priorities of its development. The mainstream of the Ukrainian energy policy must become the increase of efficiency and the development of the maneuver potentials instead of the basic ones, especially of nuclear origin. This position is shared by Ukrainian citizens, who took part in the public hearings concerning the problems of energy production policy. Such hearings were held in 12 towns of Ukraine: Nikolayev, Severodonetsk, Chortkov, Iziaslav, Piriatin, Lugansk, Nizhin, Nikopol, Slavuta, Artemivsk, Cherkassy and Marganets. Nobody of the participants ever suggested the immediate closure of operating blocks of the AES, which testifies of their common sense. On the contrary, many expressed their protest against the widening of Kh2/R4. It is consistent with the results of the poll held by SOCIS-Gallup: only 14% of the pollees supported this project.
The main conclusion of the hearing is as follows: THERE IS NO ALTERNATIVE TO ECONOMICAL SPENDING OF ENERGY IN UKRAINE! Thus, all possible internal and external resources, in particular Western credits and grants, must be directed not to building additional nuclear mastodons, but to development of energy saving.
Respected peoples deputies! We beg of you: 1) to support Ukraine in keeping her obligation concerning the closure of ChAES; 2) to turn to the General Prosecutors office with the request about the prosecutors reaction to the violations of the Ukrainian laws in financind the widening of Kh2/R4; 3) to put the moratorium on the negotiations of the government with the Europe bank of reconstruction and development about the financing the Kh2/R4 project until the state ecological expertise gives the positive conclusion and the TEC of the project is prepared; 4) to discuss in the proper committees of the Supreme Rada the situation with the TEC and the complex state expertise of the project; 5) to publish the existing variant of NEPU-2010 and invite the public to participate in discussing the new variant of this NEPU-2010; 6) to hold Parliamentary hearings for the comparison of two policies: the widening of Kh2/R2 and the investments aimed at the increase of the efficiency; to suggest to local authorities to organize similar hearings in their regions and to use the results at the Parliamentary hearings; 7) to support the government measures aimed at ordering the energy market and the development of economical spending of energy; 8) to strengthen the relations of the Supreme Rada with the public; 9) to admit to the Parliamentary hearings a representative of the Coalition For the energy safety, access to information and citizens rights, that includes our organizations, to reflect the opinion of the ecologically oriented part of the public.
The head of the National ecological center of Ukraine Sergiy Tarashchuk
The head of the Ukrainian ecological association Zeleny svit Mykola Korobko