The Ukrainian Parliament’s Committee on Energy, Housing and Communal Services has endorsed Draft Law No. 11392, which envisages the procurement of equipment for the third and fourth power units of the Khmelnytskyi Nuclear Power Plant. Initially, the draft law aimed at general energy infrastructure development and simplification of business activities. However, its content was radically altered: shortly before the vote, a provision was introduced that unexpectedly opened the door for the purchase of Russian-manufactured reactor equipment from Bulgaria.
What Happened?
On January 16, the Committee amended draft law No. 11392, which had been adopted in its first reading on July 2, 2024.
Initially, the document focused on electricity market issues, particularly simplifying grid connections. However, a large number of amendments were submitted for the second reading. Ultimately, all amendments were overturned by Amendment No. 267, and a new provision, Amendment No. 268, was added. Authored by Members of Parliament Anatolii Kostiukh, Anna Skorokhod, and Oleh Seminskyi, this provision permits the procurement of Bulgarian equipment for the Khmelnytskyi NPP power units.
According to Committee Chairman Andrii Herus, negotiations with the Bulgarian side resulted in an agreement that the decision must be made by March 12, as this is when the permit for selling the equipment expires. However, completing the power units requires a separate law based on updated feasibility studies adapted to modern conditions.
Additionally, the draft law received criticism from the Ukrainian Parliament’s Chief Legal Department, which pointed out that the law’s title does not align with its substance and should address entirely different issues than those outlined in the text. The adoption of this draft law may contradict principles of good governance.
Why Is This Dangerous?
The reactors in question are VVER-1000 units, model V-466B, manufactured for Bulgaria’s Belene Nuclear Power Plant project. Although formally owned by Bulgaria, their maintenance requires Russian technical involvement—either directly or indirectly. At a time when Ukraine is striving to eliminate all dependencies on the aggressor state, introducing legislative provisions for utilising Russian equipment seems, to say the least, a questionable decision.
Flaws of the Belene Equipment
The reactors proposed for use at the Khmelnytskyi NPP do not match the initial technical specifications of power units No. 3 and No. 4. Their integration will require extensive reconstruction, resulting in additional costs and delays. The feasibility study in question is based on data from 2019, which is now outdated. Inflation, market fluctuations in equipment and fuel prices, and the economic challenges of wartime significantly affect the cost of any large-scale infrastructure project. Nevertheless, Energoatom persists in relying on the outdated feasibility study without providing updated calculations or clear guarantees of technical independence from Russian service companies.
Risks of Dependency and Lack of Transparency
Even with the equipment formally registered as “Bulgarian,” the risk of dependency on Russian technologies for maintenance remains significant. Strategically, this creates a risk of energy dependency on a country waging a full-scale war against Ukraine. These risks should be carefully assessed and eliminated through an updated feasibility study. However, Energoatom continues to rely on an outdated document that fails to address modern technical challenges and market conditions.
The lack of transparency in decision-making processes further complicates the situation: the current decision to complete the Khmelnytskyi NPP was made before the supervisory board began its work, which contradicts the principles of good corporate governance that Ukraine must adhere to as part of its cooperation with international partners. It is the supervisory board that should ensure the transparency and effectiveness of the company’s operations, particularly in financial expenditures and strategic planning.
Despite public statements by Ukraine’s Ministry of Energy claiming international partner support for the project, such assertions appear manipulative. International partners, including the G7, emphasise the need for an independent supervisory board at Energoatom.
This indicates a systematic disregard for partner recommendations and key principles of transparent governance. The absence of such decisions from the supervisory board undermines trust in the company and raises concerns about decisions that could be disadvantageous to the state. Given the enormous funds required for modernising and adapting the reactors, independent and impartial oversight is critical to avoiding corruption risks and ensuring maximum transparency.
What’s Next?
Amendment No. 267 must be removed from Draft Law No. 11392. In its current form, the draft law demonstrates noncompliance with key democratic principles: lack of public discussion, absence of updated expert evaluations, and neglect of the risks of Russian involvement in Ukraine’s strategically vital energy sector. This step appears to be a hasty political decision that could lead to long-term technical and financial dependence on Russian technologies.
If Ukraine genuinely seeks energy security and independence, it should not fall for short-term “benefits” while ignoring their risky costs and vulnerabilities to the aggressor.