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Open letter from Slovak, and other NGO's to the directors of the EBRD, the European Commission, and the Slovak and Ukrainian governments
Date: 15 April 1997
To:
From:
Subject: Rovno 2 and Khelnitsky 4 nuclear reactors in Ukraine Dear Jacques de Larosiere, Minister Kostenko, Hans Van Den Broek, EBRD Directors, Finance Ministers, and others who will be involved in the decision-making process on the Rovno-4 and Khmelnitsky-2 nuclear power plants: The above listed NGOs from Slovakia, Austria, Poland, and elsewhere are writing to you to ask that plans to modernise and complete the Rovno and Khelmnitsky nuclear plants in the Ukraine be abandoned forthwith. The conditions for this project to which the EBRD has committed itself in statements by President Jacques de Larosiere, and in the G7 Memorandum of Understanding cannot be met. These dangerous and outdated examples of a technology from which the world is slowly but surely withdrawing should be decommissioned. Recent statements by Ukraines Minister for Environment and Nuclear safety, Yuri Kostenko, to the effect that Rovno and Khmelnitsky are to be completed to a 'Ukrainian' standard referenced to a plant that has failed to attain even Ukrainian standards of safety (Zaphorozhye-6) removes any pretence that these plants will ever attain even Ukrainian, let alone western, standards of safety. The Kostenko plan ensures the very lowest, rather than the highest, possible safety standards. In this respect, we welcome the statement by Peter Thomlinson to NGOs that 'Kostenko is wrong'. The conditions laid down in the Memorandum of Understanding as they relate to safety and economics, cannot be fulfilled., however, even under the original safety upgrade plan. Rovno and Khmelnitsky are not least-cost, and they cannot be bought up to 'western', or indeed any acceptable, safety standards. Yet major conditions for the involvement of the G7 and the EBRD are supposedly:
Likewise, the EBRD has called for the application of least-cost principles, the EC has called for a favourable technical and economic assessment, and the European Parliament has callled for least-cost studies to be made a condition for the granting of aid. Yet the independent review panel set up by the EBRD in the Science Policy Research Unit at the University of Sussex has concluded after an exhaustive analysis that: "Completing these reactors would not represent the most productive use of USD 1billlion or more of EBRD/EU funds at this time." In relation to safety, it has been said by the EU on June 23, 1994, that: "The Commission will insist that the reactors should be completed not just to Russian or Ukrainian standards, but to full western safety levels instead." I remind You, President Larosiere, that you stated that , for the EBRD to be actively involved, "The safety of any nuclear plant we would be working on would have to be at the highest existing standard." This contrasts radically with subsequent statements that the Commissions program will allow merely for the plants to be completed to "...a safety level which is equivalent to the level currently achieved in Europe for plants of the same vintage designs", This is widely presumed to be equivalent to plants designed in the west without benefit of lessons learned from Chernobyl and Three Mile Island: Surely a step backwards from even the current levels of safety at these plants! Your (Larosieres) statements contrasts radically also, with the statements of the Ukrainian Minister Kostenko, that Rovno would be upgraded to 'Ukrainian' safety standards, and only later upgraded to a higher standard. Apart from the step backwards that this represents in terms of committment by the EBRD and the EU to higher safety standards, it is impractical, or at least extremely difficult, to complete a reactor to one standard, and then perform extensive backfitting operations to upgrade parts of it to another standard after it has become operational. When backfitting of this type has been done in the US to conform to increased safety standards there, it has led to collosally expensive and lengthy rebuilding which has in some cases, taken literally decades and billions of dollars, as well as leading to significant worker exposures to radiation. Friends of the Earth Intl. has reviewed the IAEA documentation for Rovno and Khmelnitsky. Our review tells us that the safety improvements which are to be attempted for these two plants relate to deep-seated and generic design problems of VVER 1000 plants. These design problems are not readily fixable without fundamental rebuilding of parts of the plant. Even current (pre - Kostenko) proposals to upgrade the plant, focussing as they do on Instrumentation & Control upgrading, are inadequate. The Kostenko proposal removes any possibility that Rovno and Khmelnitsky will be safe by any standards at all, Ukrainian, Russian, or Western. Given all of this, we submit that the EBRD and the EC have no option but to withdraw from the project to make Rovno and Khmelnitsky operational, and should provide funds only for decommissioning these plants. Naturally, we fully support measures by the international community to facilitate the very important goal of the closure of Chernobyl through the extension of efficiency and reneable energy projects, beyond the projects already identified in the Memorandum of Understanding. We trust and hope that you will take these considerations into account in your deliberations. Signed:
John Hallam, FOE Australia .(Friends of the Earth Sydney)
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