Recent efforts surrounding Ukraine’s attempted purchase of two VVER-1000 nuclear reactors from Bulgaria highlight the complex legal and geopolitical environment in which Ukraine’s reconstruction efforts are unfolding.
Bulgaria abruptly refused to sell two Russian-made VVER-1000 NPP reactors that Ukraine planned to buy to complete the construction of the Khmelnytsky NPP. Under the original design, the NPP had to have four VVER-1000 blocks, but only two were completed in time and are operational.
The prospective purchase was quite controversial in Ukraine. To soothe the pill, the Ukrainian government even came up with the idea of further expansion of the NPP by installing two more NPP blocks, thus bringing the overall number of operational blocks to six. The additional two blocks were mulled to be AP-1000 by Westinghouse.
VVER-1000 and AP-1000 share a similar technical design philosophy but are otherwise incompatible. From both legal and engineering perspectives, deploying AP-1000 alongside VVER-1000 and making them operate within a single grid is still possible. Yet it would be quite a challenging exercise from all other practical points of view, including the increased maintenance and operational costs.
For now, it is clear that blocks Nos. 3 & 4 will not be filled in with the pre-designed VVER-1000, yet it may be possible to see AP-1000 deployed there instead within the next decade or so.
The stalled $700M deal for Khmelnytskyi NPP Units 3 and 4 raises key issues at the intersection of:
Energy sovereignty vs. cross-border procurement constraints
As Ukraine moves to expand and modernize its nuclear fleet — potentially incorporating Western technology alongside legacy systems — stakeholders will face an increasingly complex legal environment. This includes navigating state aid rules, interoperability standards, IP licensing in reactor technology, politically sensitive procurement processes, and heightened scrutiny from international donors and financial institutions.
At Kinstellar, we continue to successfully support clients in managing these challenges as part of Ukraine’s broader reconstruction effort - helping ensure compliance with international legal standards, investment protection frameworks, and governance best practices in a rapidly evolving environment.
