The international working group on the issue of sanctions against russia (the McFaul-Yermak group) in its “Action Plan...” dated April 19 provided for sanctions against Rosatom. But it is not in any of the accepted 7 sanctions packages. At the same time, the issue of Western sanctions against Rosatom is sensitive for russia, as the corporation's statement dated August 19, 2022 shows.

“We categorically deny any involvement of Rosatom or any of its employees in the management or operation of the plant at any level” – this is a quote from a letter from Rosatom to the European publication EU Observer. As is generally known, after the seizure of the ZNPP, it was declared part of Rosatom upon the arrival of its representatives on March 11, however, this was not an official corporate statement, but the relevant statements and actions by the Ministry of Defense of the russian Federation and the occupying ACA Energodar.

So, this refutation shows that the Kremlin is afraid of Rosatom falling under certain restrictions. Back in May, its head Alexei Likhachev reported to V. Putin that they “see the risks”. First Deputy Head of the Administration of the President of the russian Federation S. Kiriyenko, as the former long-time head of Rosatom, well understands that the corporation becomes an accomplice in the crime in case of official actions together with the Armed Forces of the russian Federation, i.e. A. Likhachev together with the Minister of Defense S. Shoigu and S. Kiriyenko become organizers of nuclear terror not only in Ukraine but also in Europe.

A series of actions by Western countries may be among the measures that are troublesome for Rosatom. First of all, it is said that the nuclear sphere should not be excluded from the regime of sanctions in the EU and the USA, since russia has already crossed the red line and started using civil nuclear energy as a weapon.

In view of this, it is considered appropriate and necessary:

The Ministry of Foreign Affairs of Ukraine to appeal to the governments of the EU countries and the European Commission to freeze all existing projects with the participation of Rosatom or its affiliated companies or joint ventures until the complete cessation of russian aggression and the withdrawal of occupation troops from the territory of Ukraine (officially called 36 foreign projects of Rosatom“, although half a dozen of them seem to exist only on paper).

For reference:

Although the resolutions of the European Parliament do not have a legal obligation to be implemented by the member states, the corresponding provisions of the two resolutions can be used for the purpose of political encouragement of the EC and the heads of state and government of the EU member states.

  • “Resolution of the European Parliament of May 19, 2022, on the socio-economic consequences of russia’s war in Ukraine for the EU — strengthening the EU’s effectiveness” (2022/2653 (RSP):
  • … again calls for an immediate and complete embargo on russian imports of oil, coal, nuclear fuel, and gas, as well as the complete abandonment of the Nord Stream 1 and Nord Stream 2 gas pipelines;
  • In the context of the above, the Ukrainian government should demand from the French government the termination of a number of projects and agreements with Rosatom.
  • Termination of the strategic cooperation agreement dated December 2, 2021 between the French nuclear conglomerate Framatome and Rosatom.
  • Termination of cooperation between the subsidiary “Rosenergoatom” (the operator of russia’s nuclear power plants, an analogue of NAEK “Energoatom”) and the French EDF.
  • Termination of the strategic cooperation agreement dated December 2, 2021 between the French nuclear conglomerate Framatome and Rosatom.
  • Termination of cooperation between the subsidiary “Rosenergoatom” (the operator of russia’s nuclear power plants, an analogue of NAEK “Energoatom”) and the French EDF.
  • A categorical demand to both the French government, the European Commission and the United States regarding the termination of the agreement in early February 2022 for the acquisition by Rosatom, with the assistance of EDF, of 20% of the French turbine manufacturer GEAST (a joint venture between the American General Electric and the French Alstom). Rosatom will not be able to implement its foreign projects without Ukrainian Turboatom turbines or American-French GEAST turbines.
  • Demand to stop cooperation in the production in partnership with Areva (now Orano) of heat-releasing assemblies at Elektrostal near Moscow for 7 nuclear power units in Europe.
  • Alstom’s withdrawal from the Alstom-Atomenergomash joint venture created in 2007.
  • russia should be excluded from the international project to build the ITER thermonuclear fusion reactor in France on the Kadarash plateau.

The Government of Ukraine should appeal to the European Commission and the governments of EU member states regarding the transfer of power units with Soviet-designed VVER reactors to non-russian fuel (only 18 out of 103 nuclear power units in the EU depend on russian fuel supplies. They produce no more than 10% of all nuclear energy in the EU).

Contact the USA and Canada regarding the review of the approach to the licenses previously granted by the government agencies of the USA and Canada to the “daughters” and “granddaughters” of “Rosatom”, in particular, “Techsnabexport” (international brand – TENEX) and “Uranium One” (The latter conduct extensive activities with sale and extraction of uranium raw materials, increasingly increasing the volume of supplies to the USA and Europe, creating dependencies, according to a scheme similar to that implemented by Gazprom with gas supplies to the EU countries. In fact, Rosatom, destroying competition on the world market, subordinated the production to itself of uranium-containing raw materials in Kazakhstan (the world leader) and Uzbekistan. Thus, Rosatom controls 36% of the global market. In the US alone, acting through subsidiaries, it has 25 contracts for the supply of uranium raw materials with 19 American firms until 2028 for a total in $6.5 billion. American experts indicate that Australian and Canadian mines have recently reduced production due to Russia dumping uranium prices on the world market).

A direct ban on the import of uranium to the USA from the facilities of Rosatom would be completely logical and without special consequences.

For reference:

Rosatom’s avoidance of American sanctions is largely due to lobbying by the US industry association, the Nuclear Energy Institute, which insisted that nuclear sanctions against Russia not be imposed. They falsely claimed that it was in the interest of protecting US consumers from rising electricity costs. However, independent American experts indicate that it was a fake for several reasons:

  • Nuclear fuel accounts for the smallest share (~16%) of nuclear generation costs after O&M (~60%) and capital costs (~25%).
  • The cost of mined uranium is only half of the total cost of fuel (8%).
  • Nuclear power plants buy fuel only every 18 or 24 months, and then only to replace one-third of the fuel in the reactor. Any increase in the cost of fuel affects only one-third of the total cost of fuel.

Even if the value of uranium were to double as a result of sanctions, it would increase the cost of nuclear generation by less than 3%. That’s less than the rate of inflation, and much less than the 200% increase people pay to gas up their cars.

The Ministry of Foreign Affairs and the Ministry of Energy to intensify joint actions in the EU to stop the construction project of two power units of the Paksh NPP in Hungary, where the contractor – Rosatom – was chosen to bypass the EU-mandatory tender procedure. Two in one – a blow to Rosatom and action to destroy the Kremlin’s metastasis in the center of Europe – the corruption-inducing, anti-European regime of Orban.

For reference:

An example of an adequate approach to Rosatom’s projects under the circumstances of russia’s war in Europe is Finland, which stopped the implementation of the joint project for the construction of the Khanhikivi-1 nuclear power plant in May of last year. Also, in 2021, the government of the Czech Republic blocked the participation of the russian Federation in the tender for the construction of another power unit of the Dukovany NPP.

Rosatom’s subsidiary, Atomflot, appears in the aforementioned Plan of the McFaul Group as a candidate for sanctions, but has not been subject to any restrictions. The company’s vessels, both specialized icebreakers and container ships, as well as vessels of the auxiliary technical fleet, should fall under the prohibition of activities in the ports of Europe, North America, G7 countries, their maintenance, repair, etc. Atomflot should not receive any equipment from European or American companies.

It is necessary to initiate the World Association of Nuclear Operators (WANO, head office in London) to review the activities of its Moscow center, terminating the participation of operators from EU member states and transferring them to the Paris center accordingly.

The Ministry of Internal Affairs of Ukraine has appealed to Interpol regarding the search and detention of managers and members of the Supervisory Board (9 people), the Management Board (14 people), and the Public Council (24 people) of Rosatom, as persons contributing to terrorist activities at the nuclear power plant in the neighboring the country.

Unsanctioned actions

Asymmetric decisions and actions are needed. So far, these are reminiscent of the warning of British and American parliamentarians that radiation contamination of the territory of NATO member countries activates Art. 5 of the Washington Treaty. In fact, this is another delineation of the borders for the Kremlin within the framework of the “war in Ukraine”. If the radiation does not get outside the borders of Ukraine, then there will be no retaliatory attack by NATO on the russian Federation, and within the framework of the “war in Ukraine” you can do anything you want – this is how the Kremlin will understand this message.

The Verkhovna Rada of Ukraine, together with the parliaments of a number of countries of Central-Eastern Europe and Scandinavia, call on the US Congress to complete the procedure of recognizing the russian Federation as a state sponsor of terrorism in order to prevent a dangerous scenario for Ukraine and Europe, as well as for East Asia in the event of Chinese aggression against Taiwan.

It is necessary to draw the attention of the United States that in the event of the success of the russian scenario of nuclear escalation around the ZNPP, China will use the pattern of russian actions in order to gradually, and not at once, seize Taiwan, first by landing an amphibious assault on Taiwan’s two nuclear power plants (the operational “Kuoshen” and the decommissioned “Jinshan”), which are conveniently located for landing operations on the sea coast in the northern part of the island, only 25 km from the capital, Taipei. The formal reason, as in the case of the russian invasion of Ukraine, is Beijing’s suspicion of Taiwan’s creation of nuclear weapons and the need to protect Asia from “Taipei’s nuclear terrorism.”

In the Black Sea, Russia can also take advantage of the experience gained in order to, in the event of a conflict with NATO, preemptively seize the Chernavode NPP in Romania, which is located some 60 km from the coast, and present an ultimatum to the US and NATO to take away the military infrastructure from Central Europe. A similar scenario can be developed for the Baltic Sea region, for the seaside NPPs of the newcomers of the Alliance: Finland – Lovisa and Olkiluoto and Sweden – Forsmark and Oskarhamn.

It would be worth encouraging our partners to work out non-standard measures – restricting access (blockade) to the Kaliningrad region, as well as the russian naval base Tartus in Syria. The blockade of the Kaliningrad exclave can be practiced as countermeasures in the context of the russian May exercises in the territory of the region, when “electronic” single and group launches were carried out at targets simulating missile launchers, airfields, protected facilities, military equipment accumulations and command posts of neighboring of NATO countries – Poland and Lithuania – “under conditions of radiation and chemical contamination of the area”.

Under no circumstances should Ukraine agree to options for “resolution of the ZNPP crisis” such as “recognition of Crimea as russian in exchange for the voluntary transfer of control over ZNPP to Ukraine with the withdrawal of russian troops.”

Author: Mykhailo Gonchar, Ukrainian energy and international relations expert, President, The Centre for Global Studies “Strategy XXI”

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