- Both units must achieve previously agreed nuclear safety levels before start-up and;
The post start-up safety and modernisation programme for both units must be completed in full.
- Safety upgrades of the 13 existing nuclear power units in Ukraine, using K2 and R4 as benchmarks;
- An internationally agreed nuclear liability and insurance regime;
- A decommissioning fund.
- The establishment of acceptable cash-collection rates for the state nuclear operating company, Energoatom, and for the wholesale electricity market.
- The transparent application of Energoatom's tariff methodology to facilitate the establishment of tariffs which allow for full recovery of all Energoatom operating costs.
- Continued transparent distribution of the revenues collected in the energy sector.
- Support for measures to strengthen the independence of the National Electricity Regulatory Commission (NERC), which sets tariffs.
The project has been classified B1, based on the relatively limited scope of the project and its likely environmental impact, as set out in the EBRD's Environmental Policy (2003).
Technical Support Organisation support to the State Nuclear Regulatory Committee of Ukraine in the Licensing of Khmelnitsky 2 and Rivne 4 NPP Units - follow-up (phase 1). Technical Report 1, Task 1, carried out by Riskaudit Report No.593 (2004); and
- K2R4 Project: Review of Environmental Due Diligence carried out since 2000, carried out by Mouchel Parkman (2004).
Several components of the environmental due diligence carried out prior to 2000 are still relevant for the current project. These include:
Environmental Impact Assessment for Completion of Rivne Unit 4 Nuclear Power Station (1998)
Environmental Impact Assessment for Completion of Khmelnitsky Unit 2 Nuclear Power Station (1998)
Environmental Impact Assessments for Completion of Rivne Unit 4 and Khmelnitsky Unit 2 Nuclear Power Stations. Addendum. Environmental Impact of the Non-Nuclear Alternative (1998)
- Environmental Impact Assessments for Completion of Rivne Unit 4 and Khmelnitsky Unit 2 Nuclear Power Stations. Addendum. Supplementary Information (1998)
Environmental Audit of Rivne NPP; by Mouchel Parkman (April 2004)
Environmental Audit of Khmelnitsky NPP; by Mouchel Parkman (April 2004)
- Environmental Appraisal of Modernisation Measures; by Mouchel Parkman (April 2004)
Environmental issues associated with the post-start-up modernisation project concern:
any issues identified during the "Environmental Appraisal of Modernisation Measures"
- any issues identified during the environmental audits and the "Review of Environmental Due Diligence Carried out since 2000".
The modernisation project encompasses about 70 measures. The consultants concluded that:
none of the proposed measures are likely to result in significant negative environmental impact;
any environmental impacts of the proposed measures can be minimised through the implementation of effective working procedures during maintenance and repair and for the subsequent management and disposal of waste materials.
12 could have a possible direct impact on the environment. Of these, the assessed impacts of 11 are related to the disposal of equipment arising from modernisation, maintenance and repair activities;
28 were likely to reduce the risk of accidents occurring and/or the subsequent consequences;
- 18 may have possible implications for occupational radiation exposure and will thus require adherence to ALARA principles.
3.2 - Environmental issues related to KNPP and RNPP
Both plants were subject to a general environmental audit carried out in April 2004 (see also section 2. Information Reviewed). For each site, the audit included an assessment of Structure of Environmental, Health and Safety Management; Policies, Procedures, Training and Supervision; Radiation Protection; Health and Safety; Environmental Monitoring and Control; Emergency Planning; Reporting; Liaison with the Public.
Kmhelnitsky and Rivne Nuclear Power Plants have implemented effective systems for management of environmental protection, radiation protection and health and safety. In each plant, there are dedicated departments for Environmental Protection and for External Radiation Control, a Radiation Safety Shop responsible for radiation monitoring and control within the NPP, a Labour Protection Department and an Emergency Management Department. Evidence was provided which demonstrates that policies, procedures and instructions have been approved, are supervised effectively, and that the results are fed back into associated training activities. The consultants recommended that interaction between the separate departments could be improved.
The management of environmental, health and safety and radiological protection at both KNPP and RNPP is based on well defined policies ('Reglaments'), procedures and specific instructions. Reglaments are approved by Energoatom and by regulatory authorities.
Radiation protection of NPP staff at both KNPP and RNPP is the responsibility of the Radiation Safety Shop. There are well established systems and procedures for radiation protection, in line with the requirements of the regulatory authorities, and based on ALARA principles. Some of the operating instructions may need to be changed to allow for additional operational units. Radiation exposure monitoring and dosimetry recording systems appeared to be functioning effectively.
Both KNPP and RNPP operate Labour Protection Departments with trained staff inclusive of inspectors. This area is well regulated, with clear management functions and procedures. There is induction training for labour protection. Control of NPP staff appeared to be effective, but control of contractors and induction of visitors would benefit from further improvement.
Both KNPP and RNPP have effective systems for monitoring and controlling radioactive discharges to the environment. There is extensive routine monitoring at the NPPs and within a 30 km radius of each NPP. There have been no exceedences of reference limits in recent years. Information on the relevant radiation background (based on the monitoring results) is regularly provided to the local population.
KNPP has an emergency plan that has been revised to take account of the operation of unit 2 and is currently being reviewed by the regulatory authorities. At the time of the audit it was subject to approval by the regulatory authority. The plan includes emergency procedures, including staff training and regular testing of the plan. There is an emergency shelter for staff on site, but it was designed for access by staff from unit 1. An emergency shelter for unit 2 is under construction. An on-site Emergency Control Centre exists but requires improvement to its communications facilities. It is planned to have an off-site ECC operational prior to commissioning of unit 2. An automated system for environmental radiation monitoring in both normal and abnormal operating conditions (ASKRO) is under construction.
Both KNPP and RNPP have an effective system or reporting to Energoatom and regulatory authorities on matters associated with radiation protection, environmental protection and health and safety.
Both KNPP and RNPP have an effective ongoing liaison with the local population, making use of local newspapers and local TV, and provide regular information on radiation background and emissions.
The facilities will need to meet all relevant national, EU/WBG and international industry standards and requirements (e.g. Euratom; IAEA). This will be a condition of the EBRD loan.
Environmental Action Plans are currently being developed jointly with Energoatom, based on the results of the Environmental Analysis and the Environmental Audits referred to in 3.1 and 3.2 above. These EAPs will list agreed actions agreed and will be covenanted. Implementation will be monitored by the Bank.
For the EBRD project the Bank's B level disclosure requirements will be met.
The project will be subject to EBRD's standard reporting requirements (annual environmental report prepared by the client), plus immediate notification in case of any material incident or accident.
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Text of the PIP
Project Complaint Mechanism (PCM)
The Project Complaint Mechanism (PCM) is the EBRD's accountability mechanism. It provides an opportunity for an independent review of complaints from individuals and organisations concerning EBRD-financed projects which are alleged to have caused, or are likely to cause, environmental and/or social harm.
Please visit the Project Complaint Mechanism page to find information about how to submit a complaint. The PCM Officer (firstname.lastname@example.org) is available to answer any questions you may have regarding the submission of a complaint and criteria for registration and eligibility, in accordance with the PCM Rules of Procedure.