Nuclear Power Plants - Environmental Impact Assessment (EIA)

           The object of Environmental Impact Assessment (EIA) is to give environment its due place in decision making process, by clearly evaluating the beneficial & adverse effect of a development activity on environment, including socio-economic, cultural and aesthetic concerns. Early identification and characterization of critical environmental impact allows the public and the government to form a view about environmental  acceptability of the proposed development activity. The EIA is to ensure that economic impacts of the environmental problems created by economic development are not passed on- To Others, To Elsewhere and To the Future.

Nuclear Establishment

  In India the Nuclear Establishment- Atomic Energy Commission (AEC), whose chairman is always the head of DAE, Department of Atomic Energy ( DAE ) and Other Associated Organizations- enjoys unique access to political authority and is protected from external oversight and is in a position to ensure decisions, in their favour in almost all cases. The Atomic Energy Regulatory Board (AERB) is a regulatory authority to oversee the nuclear projects from the point of view of public safety. However, DAE also exercises administrative & financial powers over AERB, which is to report to AEC and depend on the DAE for its technical staff. Therefore the functioning of AERB  authorizing & regulating radioactive discharges & radiation dose and nuclear safety and whose regulatory control starts from site selection of Nuclear Power Plant (NPP)  to its decommissioning, can not be expected to be independent and impartial..  

 Public Apprehensions on EIA Process     

   There is already widespread concern about, the potential environmental impacts of the Nuclear Power Plants (NPPs) and the effectiveness of EIA process for Nuclear Facilities. The three main components of EIA Process are a) EIA Study b) Public Consultation and c) Expert Committee that oversees Environmental Clearance.

a)    EIA Study: The Nuclear Establishment is tempted to regard EIA simply as a means of obtaining Environmental Clearance and hence there is tendency to make the environmental impacts of nuclear projects look more benign than they are. The EIA is prepared by consultants who are retained to work on behalf of and by implication act in the interests of their client proposing the project. In addition the consultants have to depend on DAE and associated organizations for data about baseline levels of radio nuclides and expected levels of radioactive discharges. This allows DAE to be completely in charge of determining the main impact of concern- environmental release of radioactive materials, which cannot be relied upon.

     If the EIA is found to be faulty/deficient at the technical/ factual levels, th proponent  should be required to go through public
    consultation  process again with revised EIA  or may even be rejected as per sub Para 8 (vi) of EIA Notification of 2006.

b)   Public Consultation.  

The experience so far regarding Public Consultation suggests that public opinion and inputs, critical of the EIAs, not to mention the projects themselves , count for little in decision making about nuclear projects. At best, the approach that nuclear establishment has taken towards the role of the public can be characterized as dealing with public participation "as a procedural issue than one of value." The public hearings for nuclear projects have always been short and rushed affairs with insufficient time for all interested and concerned participants to seek information or clarifications. The questions raised are seldom answered satisfactorily by the project proponents. For the most part, the public has also not been made to feel welcome at the hearings & many public hearings have featured massive police force.

 This has to drastically change in the case of nuclear facilities, both because of the unique characteristics of nuclear fuel cycle and because of the vast majority of the population in India has little understanding of radiation and its associated hazards. The nuclear establishment should make use of the public consultation process to improve its decision making and helping it set public fears at ease, instead of treating as a ritual to comply with the legal requirement to the barest minimum and avoid them whenever possible.

c)    Expert Committee that oversees Environmental Clearance.

An agency, completely independent of nuclear establishment, should be set up perhaps under the administrative and financial control of Ministry of Environment & Forests or Ministry of Science & Technology or proposed autonomous National Environmental Protection Authority (NEPA), and tasked with developing expertise in measuring radiation levels as well as calculating likely radiation doses to various population groups living around various nuclear facilities. Likewise the AERB should be kept outside the administrative and financial purview of Atomic Energy Commission.

  With these changes, the role of the personal from the Nuclear Establishment in the Expert Appraisal process can and should be minimized, if not altogether eliminated, progressively. As regulatory control of AERB, starts from site selection of Nuclear Power Plant (NPP) to its decommissioning, the regulatory control of MOEF, CPCB, SPCB, in respect of NPPs is limited once Environmental Clearance is accorded

 Proposed Nuclear Power Parks

     The Nuclear Power Corporation of India, is reported to have received clearance from Govt. of India, to create  coast based Nuclear Power Parks, each having  minimum of six reactors of 1,000 or 1,650 MW totaling about 10,000 MW. The likely location of Nuclear Parks- Andhra Pradesh (Kowada, Srikakulam Dt.), Gujarat (Chhayamithi Virdi), Maharashtra (Jaitapur), Tamil Nadu (Koodankulam) and West Bengal ( Haripur). The DAE put a target of 18 months ( in December 2009)  for acquiring the land, pre-project activity and creating basic infrastructure at the site, with specific Site Clearance from the Atomic Energy Regulatory Board (AERB), the active support from the State Governments for the land acquisition and the fast-track Environmental Clearance from the Ministry of Environment and Forests (MOEF)

Nuclear Park at Kowada village in Srikakulam district

      The site selection for Nuclear Power Park by AERB is very elaborate and complex exercise, involving study of enormous amount of field data. The land acquisition for Kowada NPP, if already started, without the prior site clearance by AERB is irregular. The creation of basic infrastructure at the site without prior Environmental Clearance of MOEF, will be violation of the provisions of Para 6 of EIA Notification of 2006, which stipulates that an application seeking prior environmental clearance shall be made after the identification of prospective site(s),, before commencing any construction activity, or preparation of land, at the site by the applicant.

 Zoning around NPP

    In order to ensure that, in the event of radioactivity releases from NPP, general public and environment are not adversely affected, the area around NPP is classified into the following zones:

a)    Exclusive Zone: Up to 1.5 KM around the NPP is fenced area called Exclusive Zone and is under total control of the plant.

b)    Sterilized Zone: Up to 5.0 KM around the NPP is a restricted area called Sterilized Zone. No new activity is permitted in this area. Existing activities, people, structures continue to remain.

c)    Emergency Planning Zone: Up to 16.0 KM around the NPP is called Emergency Planning zone , where usually Township, Environmental Monitoring Lab (EML) Schools, Hospitals etc  are located

d)    Impact Assessment Zone : Up to 30.0 Km around the NPP is called Impact Assessment Zone normally monitored by EML     

     The Environmental Monitoring Lab (EML) should go into operation at least 2 to 3 years before NPP goes into operation and collect monitoring data on Air, Water, Soil, Food and Biological samples for background radiation, conventional pollutants etc and on site meteorological data. This lab is expected to continue measurements for a stipulated period even after decommissioning of NPP. (Working life 50-60 yrs)

Likely Hazards from Nuclear Power Plants

            The main health hazard & environmental impact of Nuclear Power Plant could be due to radioactive discharges into Air and Water. The limits for radiation discharges and radiation dose are authorized and regulated by AERB, to ensure safety of site personal, Population living around NPP, Flora and Fauna.

Radiation Dosage

  No dose of radiation is safe and all radiation is cumulative and each dose received ads to the risk of developing cancer or mutating genes in the reproductive cells. We are exposed to a background radiation dose of about 100 millirems per year from the Earth and the Sun. It has been estimated that if 125 people receive 100 millirems per year for 75 years, one of them will develop cancer. But the Nuclear Regulatory Commission (NRC), which is responsible for the oversight of the international Nuclear Power Industry, has decided that it is acceptable for the public to receive an additional 100 millirems per year from man-made radiation created through creation of nuclear energy, doubling the cancer risk.

Emissions from NPPs

   Contrary to the nuclear industry claims, smoothly running NPPs are also not emission free. Even as per regulations stipulated, NPPs are estimated to routinely emit hundreds of thousands of Curies of radioactive gases and other radioactive elements into environment every year.

  The water that cools the reactor core (primary coolant) becomes heavily contaminated with Tritium (radioactive hydrogen) and with Carbon 14, the long term medical and ecological effects of which do not seem to be well understood. The radioactive life of Tritium is estimated to be more than 200 years and that of Carbon 14 is 114,600 years.

   A sustainable nuclear energy system would nesecciate a closed loop of Tritium & Carbon 14, such that they never enter ecosphere. At present their disposal is questionable, as they are routinely discharged into Seas, Rivers or Lakes. The primary coolant is not supposed to mix with the secondary coolant, but it normally does, allowing radiation to be released to the environment from the secondary coolant

Hazardous Nature of Nuclear Park  

    A regular 1,000 MW NPP contains an amount of long-lived radiation equivalent to that released by the explosion of 1,000 Hiroshima size bombs, which inevitably entails the release of radioactive materials into the environment.  Can imagine the magnitude of routine and accidental radioactive releases at the proposed 10,000 MW Nuclear Park at Kowada in Srikakulam district, contaminating water and food chains and expose humans and animals now and for generations to come ?. Accidents such as Three Mile Island and Chernobyl condemn thousands of people, if not Lakhs, to pay the cost of nuclear power with their own lives and health.

     In addition, the Nuclear Fuel Reprocessing Plants and Nuclear Waste Management Plants will have to be located in the vicinity of Nuclear Park. Each regular 1,000 MW NPP generates 30 tons of extremely potent radioactive waste annually, which remains radioactive for tens of thousands of years. This deadly waste material gets accumulated in huge cooling pools or in dry storage casks at NPP Sites. There is every danger of  this unconfined wastes leaching, leaking, and seeping through soils into aquifers, rivers, lakes, and seas, where it enters and concentrates in the food-chains of plants, fish, animals and humans. This is a legacy that will lead to epidemic of cancer, leukemia and genetic diseases in populations living near Nuclear Power Plants and Nuclear Waste Management Facilities for many generations to come.

US Experiences

. In USA, out of 104 nuclear power plants in operation, 27 are found to be leaking radioactive tritium into the local ground water sources. Once the ground water is thus contaminated, it is difficult to make it potable again. Radioactivity will also lead to genetic disorders & disabilities that extend over decades, as it happened in Three Mile Island in USA, Chernobyl in Russia and similar instances in Japan and other places.

     When such accidents caused major concerns in developed countries like USA where regulation and enforcement are strict, to say that they are safe in India is a highly misleading statement meant to keep the Indian public in the dark. The dangers of radioactive contamination can be understood from the fact that a small quantity of radioactive Cobalt thrown out as scrap from a laboratory in Delhi University during the first quarter of 2010 led to loss of life and injury to scores of scrap dealers.

The likelihood of accidents is higher in the case of nuclear power plants based on light water reactors which, incidentally, are going to be the technology that is going to be deployed in most of the new nuclear power projects coming up in India, especially the one at Kowada.

Conclusion

         We cannot even imagine the consequences of a Chernobyl type of accident at the proposed Nuclear Park at Kowada, in which Lakhs would perish, with radiation contamination of the entire food-chain, making a large part of the area out of bounds for ever. Should not the people of Kowada have a right even to be told, about the imminent dangers of the proposed Nuclear Park in their vicinity? 

 

        Historically disputes between Industry, Governments and Community are always Unequal and Unfair, because people who have been damaged by irresponsible industries, almost never have the expertise or funding to conduct their own studies. Governments invariably support this mindless damage in the name of GDP Growth, which is highly discriminative and not Inclusive   

 

        At this time, when our National and State Leadership is advocating Nuclear Power for Energy Security & Sustainable Development, it is important that the facts are made known to the public of Kowada area, if their lives and that of their future generations are to be sacrificed for the sake  of Nuclear Park ?