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An open letter to AEC

An open letter to AEC on the issue of Kaiga NPP expansion plan

To
The Chairman and Members

Atomic Energy Commission
Anushakti Bhavan, C.S.M. Marg,
Mumbai - 400 001


Copy to:
(1) Dr. Harshvardhan
MoEF&CC, Govt. of India, New Delhi  

(2) Dr. Jitendra Singh,
Union Minister of State, Prime Minister's Office,
Govt. of India, New Delhi  
(3) Prime Minister,
Govt. of India, New Delhi

Dated, 23rd Dec. 2018

Dear Sirs,

Greetings from Sagar, Western Ghats, Karnataka.

This has reference to the public hearing under the EIA Rule 2006 of MoEF&CC, which was held on 15.12.2018 at Mallapur-Virje, Karvar Taluk, Uttara Kannada district, Karnataka over the Environmental Impact Assessment (EIA) report of the proposal on Kaiga NPP extension (Units 5&6).

Having gone through that EIA report, and having made both written as well as oral submission at this public hearing, I notice that there are very many concerns to the local stakeholders as well as for the state and the country as a whole from the proposed project.

Whereas multiple deficiencies in the EIA report are glaring from different perspectives, such as safety, technical, economic, environmental, logistics etc., few deficiencies clearly stand out, and can be treated as adequate grounds for the MoEF & CC to summarily reject the EIA and the EC to the project.  EIA is found to be seriously deficient in not considering: (i) the details and costs associated with the additional transmission lines required for the project; (ii) adequate details of disaster management plan to safely evacuate more than 32,000 people of the region and rehabilitate them satisfactorily in the case of any unfortunate nuclear accident of the type noticed at Chernobyl and Fukushima; (iii)  policy and details  associated with the safe disposal and long term storage of spent nuclear fuel;  (iv) “options analysis” and “ costs and benefits analysis” of various techno-economically feasible options of much less overall cost available to our country in meeting the electricity demand; (v) to establish beyond reasonable doubt the project is the best option in the larger context of the region, country and the planet.

One can notice a lack of professionalism in the way EIA has been prepared, and hence, the same cannot be treated as fully establishing the true relevance of the project for the overall welfare of the society.

A serious issue noticed during this public hearing was the unanswered questions over the adequate preparedness on part of the concerned authorities during a scenario of uncontrolled radiation emission beyond the exclusion zone as can be expected in a large size nuclear reactor site such as in Kaiga NPP, and in a scenario similar to what happened in Chernobyl (USSR) and Fukushima (Japan).  During my oral submission I raised this issue with the Deputy Commissioner (DC) of the district, who was at the Chair during that meeting.  DC chose not to respond to this issue, and hence, it is not clear whether district administration has realised the huge importance of this particular issue of adequate preparedness on disaster management associated with a nuclear accident.

The EIA is without the necessary details in this regard, and seems to be keen to pass on all the associated responsibilities to the district administration, which shall not be acceptable to the people of the state. The following is the corresponding text in EIA.
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EIA Section 07.06.04: Off-site emergency  
"An off-site emergency occurs when the radiological consequences of an emergency situation originating from Nuclear Power plant (NPP) are likely to extend beyond the site boundary (exclusion zone) and into the public domain. For the purpose of planning off-site emergency, an emergency-planning zone up to 16 km radius is specified. There are defined criteria to determine an off-site emergency in terms of the release of radioactivity as indicated by the radiation monitoring system/radiation survey results.  The protective measures in public domain shall be implemented by the district officials under the supervision of the district collector or the divisional commissioner, who shall be designated as the Off-site Emergency Director (OED)."      
   
Action plan for declaration and termination of off-site emergency 
"If there is an escalation in the site emergency situation warranting an off-site radiation emergency, the SED advises the OED to declare off-site emergency. District commissioner, Uttara Kannada takes over the charge of OED and initiates appropriate actions. Off-site emergency is declared by the OED on the advice of SED. Off-site emergency is terminated by off-site emergency director on the advice of off-site emergency response co-ordination committee."   
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With the proposed increase of about 250% in the overall reactor capacity at the project site, the Kaiga site will face exponential increase in radiation emission risks with the presence of six nuclear reactors in close proximity with each other and sharing many technical services. Nuclear safety experts identify such a scenario as "enhanced risk for NPPs with multiple reactors and shared technical facilities".

The impact of the vastly increased radiation density (because of the 250% increase in nuclear reactor activity?) on the bio-diversity and the people working and living in the project area cannot be anything but negative.  Additionally, the risk of any unfortunate nuclear accident can only multiply because of the need to store on site the vastly additional quantity of highly radioactive spent fuel for hundreds of years (India has no known policy, as yet, to store the spent nuclear fuel and other wastes away from the nuclear reactor site).

It is a general public opinion that the concerned authorities in the country are ill-equipped and ill-prepared to face such industrial level disasters as experienced in the case of Bhopal gas tragedy in 1984. Our authorities seem to become complacent over a period of time with the view that such a disaster may not happen in our country.  Whereas, the nuclear power authorities may continue to claim the low probability of an uncontrolled nuclear radiation emergency in India, such statements from our authorities do not enjoy the trust of the people because of the plethora of reports from around the world on the unmitigated nuclear disasters experienced at Chernobyl and Fukushima.  The EIA, itself admits that such an emergency cannot be completely ruled out.  Even though the probability of an uncontrolled nuclear radiation emergency in Kaiga NPP may be low, as per the claims of EIA, the overall consequences of a nuclear disaster to the district and to the state of Karnataka as a whole can be horrendous.  Hence, we cannot afford to ignore the need for taking all possible precautions, including even the minutest step, in disaster preparedness.

In view of the increased probability of a nuclear mishap at Kaiga NPP, it is essential to note what Dr. A Gopalakrishnan, former Chairman of Atomic Energy Regulatory Board (AERB) has to say on safe practices in nuclear industry in India: “Japan (which failed to avert the Fukushima disaster) is a country that has a superb disaster management organisation throughout their nation, and an often-rehearsed working team to handle such emergencies.  In contrast, in India, we are most disorganised and unprepared for the handling of emergencies of any kind of even much less severity. The Atomic Energy Regulatory Board’s (AERB’s) disaster preparedness oversight is mostly on paper and the drills they once in a while conduct are half-hearted efforts which amount more to a sham.”  An insightful article, “The missing safety audits” by Dr A Gopalakrishnan poses many serious concerns on the safety aspects in the nuclear establishment of the countryAs a welfare society with a hugely dense population and already stressed natural resources base, we cannot afford not to take cognizance of such concerns by a former Chairman, AERB, who also is recognized as an expert in nuclear power engineering.  We cannot expect the Civil Society to be rest assured until all the concerns raised by such experts are addressed satisfactorily before we consider building more nuclear reactors.

Whereas, the project proponent through EIA, seem to have shifted the actual responsibility of off-site emergency measures to DC by the statements as mentioned above, it should be emphasised that as the district administrator and also as the district magistrate, the DC has enormous and varieties of responsibilities even during normal times. It will be seen as the abdication of responsibility on part of the nuclear industry authorities in the country to expect a busy official, such as DC of a district in Karnataka, to appropriately react to a nuclear emergency unless he is ably assisted by a group of competent people, who are well trained and well equipped.  EIA has no explanations in this regard.

In this overall context, it is important to know at what stage of any unfortunate nuclear accident will the affected communities have to be evacuated, and what are the proposed arrangements for the same?  Where are the hospitals to treat the maximum of 30,252 persons (as per section 3.9 in EIA) and how will these people be evacuated and transported? Have all the families who are likely to be affected, and their habitats accurately identified, and whether adequate numbers of all-weather roads available to evacuate them at a short notice, say in mid-rainy season?  What sort of radioactive danger communication facility to each one of these people is available at present in the unfortunate scenario of a Fukushima type accident?  Where are the safe nuclear shelters to house these people?  Are the local authorities such as the Deputy Commissioner, Tahsildars, Panchayats, Doctors, nurses, community leaders etc. trained and provided with necessary equipment to detect any radiation leakage, and to take the necessary safety measures immediately?  Have sufficient number of vehicles identified and available at short notice to evacuate these people to safety?  Are all these details properly recorded and made known to the concerned group of officials/people?  

AEC should know that the district of Uttara Kannada in Karnataka is largely a hilly area, and the Kaiga NPP is in a valley surrounded by thick forests. The local communities, who are also the project-affected people, are spread over an area of about 800 sq. kM, as identified by the EIA. Since the habitats of these communities are in vastly undulating hills and river valleys, artificial reservoirs etc., and do not have well connected all-weather roads, quick evacuation in an emergency scenario will be a nightmare. As stated by the MLA of Karwar constituency in the public hearing, one of the urgent requirements of the local communities is a good number of well connected all-weather roads. The Kaiga NPP authorities should be asked to effectively work with the state govt. to share the costs and responsibility of building such a road network on a priority basis. 

Since adequate remedial actions are critical during the first few hours of any nuclear emergency to minimise the loss of life, and since NDRF and SDRF teams are unlikely to be at the site during this period, there is a critical need for the state govt. to diligently consider all the associated issues, discuss with the NPCIL/DAE/AEC/NDRF officials, and ensure all the necessary measures are in readiness.

The horrors of Chernobyl and Fukushima disasters must have been the suitable wake-up calls for our authorities to honestly try and reduce the chances of such catastrophes in India, but sadly these authorities are continuing to add more nuclear reactors at an ever increasing pace, thereby escalating the risks associated with nuclear disasters.  Since, it will be the people of the Uttara Kannada district and of the state who will bear the brunt of such a nuclear disaster at Kaiga NPP, which has been thrust on the state basically because of the policy blunder of a previous govt. to allow such a risky project in a such a hilly area covered with thick forests, it is of paramount importance for the present govt. to take all possible measures to minimise such risks and impacts.

I also understand from other nuclear project areas in the country, that the project affected people in all such cases have taken the view that the general approach of NPCIL to the disaster management preparedness has been one of clear abrogation of its responsibilities.   

In this context, it can be said to be a great disservice to the people of this country that DAE/AEC is going ahead with the addition of many nuclear reactors without ensuring adequate disaster management preparedness.

The claim by the project proponent that there will be no need to acquire additional land and the right to use more of fresh water for the proposed project, since the same have been agreed to in 1990s by the govt. of Karnataka, should carry no real merit because such natural resources belong to the people of this country/planet, and cannot be effectively replaced in any way.  The natural resources base in the state, country and the planet as a whole have undergone huge transformation since 1990s, and the scenario now can be described as one of severe crisis as referenced to the Climate Change perspective.  Karnataka, as a state, is already water scarce, and is facing drought in more than 50% of its revenue subdivisions every year.  
The fresh water demand for nuclear plants should be of particular concern for a water deficient nation like India, and for a drought prone state like Karnataka.  Nuclear reactors are known to require about 720 gallons of water per megawatt-hour of electricity they produce, according to data from the National Energy Technology Laboratory in West Virginia cited in 2012 by the magazine New Scientist. That compares with the roughly 500 gallons which coal power requires and 190 gallons which natural gas needs to produce the same amount of electricity.  Solar plants, by contrast, use approximately >20 gallons per megawatt-hour, mostly for cleaning equipment, according to the Solar Energy Industries Association. In his context, can the state of Karnataka, which has faced drought scenario in about 50% of its revenue sub-divisions in most of the years since year 1990s, afford to divert 6,346 cubic meter per hour of fresh water, as consumptive use, for the said project (as per EIA report)?.  Additional fresh water demand of 6,346 cubic meter per hour for consumptive use for the proposed project is truly enormous quantity of fresh water from the perspective of the basic needs of the people of the state.  At the rate of 6,346 cubic meters per hour the water consumption in a day will be 152,304 cubic meters of fresh water.  At about 100 litres per day this can meet the daily water requirement of about 15 lakh people.  It will be a great disservice to the people of the state to deny this much of fresh water for them, since more the 53% of the state’s geographic area is officially declared as drought prone.

The availability of water for a nuclear power project has always been a major problem, particularly for those nuclear plants located far from the coasts and dependent on freshwater. Another associated problem is the temperature of the water that’s available for cooling purpose. It is well known that many nuclear power plants in US and Europe were forced to shut-down due to either low water levels in the rivers and/or due to increased inlet water temp. The phenomenon of Climate Change, which is credibly projected to impact a tropical region like India, will have enormous impacts on both the availability of fresh water and the temperature of water in the Kali river. The heat wave that struck Europe in the summer of 2018, had forced utilities to scale back electricity production at nuclear plants in Finland, Germany, Sweden and Switzerland. In France the utility EDF >shut down four reactors in one day for this reason.  Such risks, not only from the perspective of the loss of electricity generation but also from the perspective of the loss of cooling system for the reactors, must have been analysed diligently in the case of Kaiga NPP too, which can be realistically projected to face such problems in its economic life time.  And hence, the risk of failure of the safe shutdown of the reactor cannot be underestimated. 

The region around the Kaiga NPP, which also has an important river Kali flowing through it, is ecologically very sensitive, and is considered to be of very high ecological value. This area, around Kaiga NPP including the three villages of Kaiga, Mallapur and Virje, which are identified as project area in the EIA, is anyway declared as Ecologically Sensitive Area by a recent notification (3rd Oct. 2018) of the MoEF&CC. The decision to set up the Kaiga NPP in such an ecologically sensitive region in early part of this century itself was an enormous policy blunder, which has resulted in incalculable ecological impact. Three reports from the scientists of IISc, Bengaluru under the title, (i) “Ecological Sustainability of Riverine Ecosystems in Central Western Ghats”,2018; (ii) “Stimulus of developmental projects to landscape dynamics in Uttara Kannada, Central Westen Ghats”, ELSEVIER, 2016, and (iii) “Salient Ecological Sensitive regions of Central Western Ghats, India”, Springer Nature 2018, have all copiously highlighted the ecological importance of the area around Kaiga NPP.  This emphasizes the need for the review of existing forest policies to ensure sustenance of ecological services through the sustainable forest management strategies

Many such reports have established that the cover of evergreen to semi evergreen forest in this region has come down from about 62% to 39% between 1973 and 2016. In view of the ecologically sensitivity of this region, such study reports have strongly recommended the prohibition of certain human activities, which includes the setting/expansion of nuclear and hydro power stations, where withdrawal of large mass of water from Kali river in involved. In this context, withdrawal of additional large quantity of water from the river Kali (as needed for the Units 5 & 6) should be prohibited even though the EIA says that the state govt. of Karnataka has earlier approved the withdrawal of Kali river water needed for the entire Kaiga NPP.

In this context, the diversion of more than 54 Hectares of thick forest lands in this district for the proposed project (in addition to the forest lands needed for additional transmission lines) will negate the very objective of MoEF&CC and the state's own ecological considerations, in the context that the proposed project area is in the reserved forest category, and also within the buffer zone of the Kali Tiger reserve.  The forest cover in the state and the country is already known to be less than 20% as against the national forest policy target of 33% and 66% in the hilly districts such as Uttara Kannada. 

Keeping all these factors in proper perspective, it is evident that the area in and around the proposed project area is ecologically of very high value to the nature, and sensitive too, not just for the forest dependent locals, but also for the global concerns on Climate Change.  MoEF&CC has been very emphatic that such areas must be protected, and hence must be insulated from all kinds of developmental projects.    The state, the country, and the planet as a whole, cannot afford to lose more than 54 Hectares of tropical rain forest of very high ecological value to the nation’s and planet’s environment for the sake of an inconsequential additional power, as in the case of this project proposal.   

Any commitment of the state govt. to allocate the additional quantity of 152,304 cubic meters of water per day to this project should also be seriously viewed in the context of potentially reduced availability of water in Kali river due to the impacts of Climate Change. Once committed, the nuclear power plant will continue to demand this much of water per day even during water availability crisis in the river, leading to a scenario where that much of water has to be given to the project even at the cost of the basic/domestic needs of the local communities.

Objectively considering various constraints of the prevailing state and the regional electricity grids, the proposed capacity of 1,400 MWe from this project will basically mean that on an average only about 800 MW of power will be available for the end use consumption, and that Karnataka's share can only be about 400 MW of additional power. The question that should be carefully discussed is whether the state should lose more than 54 hectares of thick forests and about 152,304 cubic meters of fresh water per day from Kali river for a meager benefit of 400 MW, for which there are many benign alternative options available for the state at much lower overall costs to the state. 

The EIA’s efforts to project the nuclear power as economically viable, and that it has a relevance in the Climate Change context, can be seen as hilarious to say the least.

These and many other concerns are discussed in the written submission as in the enclosed file. Since decades, AEC/DAE has chosen not to respond to various questions raised by the civil society w.r.t the relevance of nuclear power to India, and hence, they cannot hope to get any support from the larger civil society for the nuclear capacity expansion plans.

Considering all these issues in the overall welfare perspective of the true welfare of the people of Uttara Kannada district, the state of Karnataka and the country, and in the context that nuclear power is the costliest, riskiest and least favored electricity option around the world, and that there are much benign and much less costly options to meet the legitimate demand for electricity in our country, the AEC/DAE should ask NPCIL to withdraw its application for Environmental Clearance to this project proposal.

Under the prevailing scenario in the country and the planet, as detailed herein, it will be a travesty of social and environmental justice, and the violation of the provision of the country’s Constitution and provisions of many relevant Acts of the Parliament to allow the diversion of more than 54 hectares of dense forest land of very high ecological value, and 6,346 cubic meter per hour of fresh water which can meet the daily needs of about 15 lakh people to this enormously risky project.

The over ambitious plans of the govt. to expand nuclear power capacity in the country against all wisdom should also be dropped in favor of the vastly attractive, least costly and environmentally sustainable renewable energy sources.  

The detailed submission made at the public hearing on all the associated issues is as in the enclosed file.

I am marking this communication to the state govt. of Karnataka, PMO and MoEF&CC.

Regards

Shankar Sharma
Power Policy Analyst
Banashankari Krupa, 3rd cross right side, 80 ft Road
Vijayanagar 1st stage, Sagara, Karnataka - 577 401
Phone: ++ 91 94482 72503

shankar.sharma2005@gmail.com
shankar.sharma2005@hotmail.com

Frontier
Jan 6, 2019