Sir,

I was really surprised to find in the latest issue of the Kyiv Post both the editorial End the Monopoly and the article Fuel Duel.  

First, I was surprised by the ungrounded accusations against the Ukrainian nuclear safety regulator. Second, it seems strange that nobody bothered to ask our comments on the issue, but probably my knowledge about ethical standards of journalists is quite outdated.

Now let me comment on some issues.

First of all, both the article and the editorial contain a number of substantial errors. So let me tell you about some facts from real life and not from sci-fi.

Given that the first nuclear power plant began operating in Ukraine in 1977, the country has a long history of using nuclear power. In the 1990s numerous events involving fuel performance were reported, prompting the original manufacturer of nuclear fuel – Russia’s TVEL – to invest significant efforts into improving fuel performance, so we are experienced in dealing with new modifications of nuclear fuel. Eventually a procedure was established to ensure that before commercial operation we had to get proper evidence that safety would not be compromised.

We have followed this procedure, for example, with the TVS-A type fuel assemblies since 2003, when the first reload of 42 TVS-A was put into the core of the Zaporizhia Nuclear Power Plant-3, together with a previously modified TVS-M. The following years saw further reloads.

The same approach was applied to TVS-W, with one significant difference: in all cases of TVEL–manufactured fuel our request was that a trial operation had to begin first at a Russian nuclear plant, and they always complied at least a year in advance. So, in the TVS-W case, we brought more risks to ourselves.

However the mixed core itself was an important feature of diversification (otherwise any nuclear plant, before changing suppliers, would have to get rid of all partially used fuel which would not properly incentivize real diversification).

Taking into account that the TVS-M, which was correctly stated as similar to the TVS-W by design in your article, already had a successful experience of operating in a mixed core with the TVS-A, major problems were not expected.  

Yet when Energoatom signed the contract with Westinghouse on the commercial supply of TVS-W long before the end of trial runs, the State Nuclear Regulatory Inspectorate expressed its concerns, as they would be expressed in any case of commercial supply of fuel which had not received clearance for commercial operations, irrespective of the manufacturer or any political or economic considerations, because of the regulator’s duty to prioritize safety. We also remained cautious in regards to extending the trial operation on additional units on the same grounds.

In 2012 it was the operator (Energoatom) who detected mechanical damage to a number of TVS-W assemblies following an established procedure of visual inspection at both units (by the way, according to the latest updates from the South Ukraine Nuclear Power Plant, another three damaged TSV-W were detected on July 6-11, 2013, under scheduled core unloading at unit 2).

Then, following standard investigation procedure, a root-cause of the event was defined by the commission, namely some construction shortcomings of the TVS-W, and taking into account that Westinghouse made a significant effort to adapt the assemblies, this conclusion was accepted by the manufacturer. Now we are in the process of a regulatory review of the Energoatom proposal to restart the trial use of modified TVS-W, and I sincerely hope it will be successful.

As for the “21 TVEL assemblies (that) were discovered to be defective in Ukraine,” there were only twoevents, both at the Khmelnitsky Nuclear Power Plant, involving fuel issues (in which the assemblies have reached the fuel damage criterion), however in both cases the root cause was not related to the fuel itself. To state otherwise would mean to propagate misinformation. 

Basically, the TVS-A is considered an advanced fuel design which resolved some mechanical drawbacks of the TVS-M.

Finally, I would like to emphasize that the State Nuclear Regulatory Inspectorate performs its duties in an open and transparent manner and following the same approach as European regulators, which was confirmed by numerous peer review missions in recent years. Our primary and only concern is nuclear safety, attention to which can never be overestimated in the country that experienced the Chornobyl disaster. I remain open for media and public dialogue and scrutiny on the subject of our competence; however technical problems could be solved by technical means only, but not by any kind of witch–hunting.

Olena Mykolaichuk, State Nuclear Regulatory Inspectorate of Ukraine Chairperson