Reprocessing of Spent Fuel from NPPs?

 

 Spent Fuel Rods from NPP

 

Each regular 1000 MW Nuclear Power Plant (NPP) is estimated to generate 30 tons of extremely potent radioactive waste annually, in the form of spent fuel rods. These fuel rods are normally confined in huge cooling pools at reactor sites or in dry storage casks beside the reactor. As these rods emit very lethal dose of radiation and are also extremely thermally hot, they must be stored for 30 to 60 years in a heavily shielded building and continually cooled by air or water.

Finally after an adequate cooling period, the fuel rods must eventually be packed into a container by remote control, for transportation to safe waste storage facility. The spent fuel packaging and its safe storage for periods of time, almost beyond our comprehension, are completely new and relatively untested, for which there does not seem to be any operational data.

The problem of permanent and safe disposal of highly radioactive nuclear material is everywhere, currently practically unresolved.

Reprocessing of Spent Fuel?

Addressing the apprehensions about storage and safe disposal of spent fuel rods from Nuclear Power Plants, the NPCIL is reported to have said that the entire spent fuel is not treated as waste. The storage capacity of spent fuel rods generated for more than seven years of full operation of reactors will be available at the NPP Site. After this time, the spent fuel    can be transported to a national facility for reprocessing to recover useful nuclear fuel.

Facts behind Reprocessing ? 

The spent fuel from NPPs is reported to consist of 96% non-disintegrated Uranium and 1% Plutonium. The rest of the contents are known to be non-recyclable fission products such as Ruthenium, Rhodium and Palladium. In the reprocessing plant, these fuel elements are fractionalized into pieces, the radioactive contents separated through solution process and the individual components isolated. Plutonium, Uranium and other fission products are now almost completely isolated and available. The isolated Plutonium is processed into so-called "mixed oxide fuel".( MOX), in order to be able to generate electricity. The reprocessing of uranium is not currently viable due to its impurity.

Reducing  Waste by 1% at what Cost ?

The amount of waste will be reduced by only 1%, since only the Plutonium content of the waste product is re-used. The term "Recycling" is therefore misleading because 99% of the original waste material remains in the form of non-usable, high-level waste solution.  

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Rule of Law - Impediment for Economic Growth?

 An Impediment?

Dr.Manmohan Singh, Prime Minister, inaugurating international conference on "Economic Growth and Changes in Corporate Environment in Asia" is reported to have made certain observations regarding Supreme Court Judgments and their impact on economic growth.

"As recent judgments have shown, the adjudication of rights and claims between parties, including between state actors and non-state parties, has wide implications for the economy and can no longer be viewed in isolation.—Therefore, Judges of the 21 st century have to be social scientists, economists, political thinkers and philosophers"

A Stimulant?

Around the same time, Justice S.H.Kapadia, Chief Justice of India, is reported to have rejected the notion that the "Rule of Law" was an impediment to economic growth, terming it instead the 'single largest" stimulant factor. Further, a "minimum standard of fairness" was being ensured only through the "Rule of Law" 

Justice Kapadia is also reported to have said, with apparent reference to "Coal Gate", the basic fact is that Loss is a matter of Fact, where as Profit or Gain is a matter of Opinion" 

In the absence of economic literacy, coupled with legal literacy, "government institutions will suffer---in terms of democracy and the economy will be in peril."  He said, The Constitution had mandated that the Government to"-strive for economic democracy" and without it "political democracy will be in peril.

Ground Realities:

The present Government Policies, which tend to circumvent the "Rule of Law" particularly the Environmental Law, in the name of rapid economic development, are resulting in the concentration of wealth and means of production to the common detriment, going against economic democracy , social order and welfare of the people, in utter disregard to the constitutional obligations. 

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Kolleru -Pelicans may loose their Paradise Again

With Dr. Azeez Committee not acceding to the proposal of AP Legislative Assembly for reduction of boundary of Kolleru Wild Life Sanctuary(KWLS)  from +5 to +3 contours, the political vested interests seem to have  shifted their pressure on to District Collector, Krishna district . As per the press reports, the District Collector asked Kolleru Wildlife Division Officials to demarcate the so called disputed area of 2576.79 hectors, within the limits of 3 villages of Kaikaluru Mandal, as they were omitted in the Notification for KWLS ( G.O.120 of October 1999), even though they are within +5 contours.

 

Pelicans may loose their regained Paradise at Atapaka

 

 The Grey Pelicans, which once populated Kolleru Lake, disappeared from there, with large scale encroachment of the Ramsar Site for aquaculture. The birds returned to the lake to nest after a considerable gap, only after fishponds were dismantled during "Operation Restoration of Kolleru" in 2005. The Environmental Education Centre (EEC) established by Wildlife Division in an area of 260 acres of dismantled fish ponds, at Atapaka village near Kaikaluru, had become a "Paradise for Pelicans" once again. Watching the vast water spread, dotted with bunds providing habitats and  nesting facilities for sizable number of migratory birds is like a dream coming true and KWLS has again become live for migratory  birds.

 

Once the so called disputed area to an extent of about 7,600 acres is demarcated as claimed by the vested interests, the EEC at Atapaka, the Paradise of Pelicans, left with only 2 acres of land will be doomed without nesting place. 

 

Early Action Required

 

 An early action be initiated for speedy implementation of the recommendations of Dr.Azeez Committee, in a given time frame, because of the importance and urgency of the issue emphasized by the Committee.  Pending initiation of follow up action, the District Collector Krishna district and other concerned agencies be restrained from pursuing the demarcation of the so called disputed area of 2576.79 hectors in Kaikaluru Mandal-Nesting Place in EEC, Atapaka.   

                  

 

             "Paradise for Pelicans"- Nesting Place in EEC at Atapaka

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Kudankulam NPP- Validity of E.C Granted in 1989?

EIA Notification S.O.60 ( E ) dated 27-01-1994

According to Sub-section (2)(III) (C), the Environmental Clearance granted shall be valid for a period of 5 years for commencement of the construction or operation of the project.

EIA Notification S.O.1533 dated 14-09-2006

According to Section 9, the "Validity of Environmental Clearance" is meant the period from which a prior environmental clearance is granted by the regulatory authority, or may be presumed by the applicant   to have been granted under sub paragraph (iv) of paragraph 7 above, to the start of production operations by the project or activity, or completion of all construction operations in case of construction projects (item 8 of the Schedule), to which the application for prior environmental clearance refers. 

 MOEF, GOI Letter No.J.14011/1/88- IA.11 (M) dated 06-09-2001 addressed to Director (K K-LWR) , NPCIL

"Ministry has noted the chronology of events of appraisal of  the project , the progress made on implementation of the project, both in construction activities as well as the compliance to stipulations made in our environmental clearance letter of even number dated 9 th May 1989 The undersigned has also visited the site on 31 st August 2001 It was observed during the visit that the land acquisition has been completed and construction work on various components such as Township , Environmental and Health Research Centre , RO Plant etc. is in progress.------ In pursuance of the discussions at site, NPCIL has now submitted, vide its letter of 5 th September, 2001 details of expenditure and commitment made till August 2001 to the tune of Rs.37,727.26 Lakhs for Kudankulam Atomic Power Project"   

"Keeping in view the steps already taken to implement the project, the Environmental Clearance issued in May, 1989 stands valid and there is no need to conduct public hearing and seek fresh environmental clearance----"

Points to be addressed

1) The first Environmental Clearance (EC) for K K-1&2 units was granted on 9 th May 1989, 23 years back prior to issuing EIA Notification S.O.60 (E) dated 27-01-1994, which stipulates E C Validity for a period of 5 years for commencement of the construction or operation of the project. This is rather vague-what is meant by construction?

Even assuming 5 years for "Commencement of Construction", KKNPP should have started construction latest by May 1994, which does not seem to be the case, judging by MOEF appraisal in September 2001. The expenditure commitment made even till August 2001, was to the tune of Rs 37,727.26 Lakhs, seems to be meager, when compared to the massive expenditure for units 1&2 of KKNPP. The ground reality as on May 1994 remains a big question mark?  Therefore the validity of EC in 2001 and beyond is questionable?

2) According to EIA Notification S.O.1533 dated 14-09-2006, the validity of EC is for a period of 5 years from the date of granting prior environmental clearance till the start of production operations. Even assuming the base date as 14-09-2006, the date of issue of EIA Notification S.O.1533, at least one unit of KKNPP should have been commissioned by 14-09-2011 ? 

3) The stipulations made by MOEF, while granting EC more than two  decades back , particularly with regard to Radiation Hazards in the vicinity of NPP, the Risk / Disaster  Management Plans etc may prove to be grossly inadequate,  taking into account the Chernobyl and Fukushima Nuclear Power Plant Disasters ? 

Therefore extending the validity of EC granted on 9 th May 1989, more than 23 years back, nearly half of the estimated useful life of a Nuclear Power Plant, needs to be examined / reviewed  whether it stands to Legal Scrutiny, Safety Standards, Aspirations of the Stakeholders in the Plant Vicinity  etc ?

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Coal was Not Sold - It Is Only Used!

 One of the Union Cabinet Minister, speaking on behalf of the Government, is reported to have said that Coal was never sold from the Blocks allotted, as the coal cannot be sold under the Nationalization Policy. So there was no question of anyone benefiting from Coal Blocks allocation.  

But at the same time, he is reported to have rejected the demand for cancellation of the licenses for Coal Block allocations; as such a step would cause huge monetary loss and badly affect the country's Power Sector.

 Monetary Loss for Whom?  

If the mineral continues to remain in the Coal Blocks and is not sold when ever it is extracted, why should there be huge monetary loss by cancellation of the allocation licenses and to whom?

The Parties, who got the benefit of licenses for Coal Blocks, must have drawn huge amounts as advances from the Banks against the guarantee of the lucrative Coal Blocks. Now we know the reason for the fears of the Minister for cancellation of the licenses and who are the likely beneficiaries?

Not Sold but Used!

The Goods and Services are produced with a value addition, so that they can be sold / used / utilized to cater for the needs/services of the users/consumers.. The Coal is one such item which can be used for generation of Power, production of Steel, Cement etc. Thus the licensees for the Coal Blocks, who have the rights to mine and use the coal, get benefited even without selling Coal.

 The coal obtained from these licensed blocks, allegedly at a very low license fees, for captive consumption, will be comparatively cheaper than the coal purchased / imported from other sources. Therefore the cost of production of the end products will be comparatively much lower than the ones produced using coal at the open market prices.

The other aspect is what is the guarantee that the coal mined from these Bocks is going to be utilized for Captive Use only? The word "Captive" can disappear, as in the case of notorious " GALI -IRION ORE" Mining Lease in AP State!

Thus, Coal may not be sold, yet the Licensees of Coal Blocks, may get benefited, by the policy of allocating licenses in a non-transparent manner.    

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Change Design of Polavaram Dam- Likely Watery Grave for 460,000 People

 

 Despite repeated objections from Experts, Civil Society, Political Leaders etc. over the present design of the Head Works (Dam) of Polavaram Project, conceived seven decades back, the State Government is going ahead by finalizing tenders for Polavaram Dam, while Govt of India seems to remain a silent spectator.

 

Background of Polavaram Project

 

The Polavaram Project, which is now being implemented with certain modifications, was originally conceived in the composite Madras State, based on the investigations made up to 1941. It was subsequently revised in 1978, 1985, 1996 & again in 2005. The Implementation of the Project with present design of the Dam, involving submergence of vast areas of land particularly Tribal Hamlets & Lands and Forest Area including that of neighboring States, has serious adverse social and environmental impacts.

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Going ahead with the present design of the Dam without even examining the possible viable alternatives to mitigate adverse impacts, undermines the intra-regional equity in the State of A.P, apart from going against the Constitutional Obligations -Articles 48-A & 51-A (g), The Environment (Protection) Act, 1986, Forest Rights Act, Tribal Consent Act etc. and ignoring the aspirations and the needs of the stake holders, the ground realities, the technological innovations etc. 

 

 Polavaram Project Dam goes against "Precautionary Principle"                                          

 

 According to universally accepted "Precautionary Principle" forming part of  1992 Rio Declaration- if an action or policy has a suspected risk of causing harm  to the public or to the environment, in the absence of scientific consensus that  the action or policy is harmful, the burden of proof that it is not harmful falls on  those taking the action or policy decision. The decision-makers are required to anticipate harm before it occurs.

 

 According to expert opinion, the proposed Earthen Dam designed for Possible Maximum Flood ( PMF ) of 50 Lakh Cusecs, falls very much short of likely extraordinary flood of 90 Lakh Cusecs. In such an event the Breach (Dam Break) of the Earthen Dam is very much real and not hypothetical. "If there is a possibility for a failure to occur, it would certainly occur sometime or other" 

                                                         

To day's  Policy and  Decision Makers, will be playing with the lives of about 46 Lakh people living in the delta down stream of the Dam,  by opting for Polavaram Earthen  Dam, without giving due consideration to the alternatives being proposed. This is in utter disregard to universally accepted "Precautionary Principle", which is nothing but a Criminal Act on their part.

 

 Objections from Orissa and Chhattisgarh States

 

As long as there are submersions, mostly tribal habitats, in Orissa and Chhattisgarh States, there is no way of getting the consent of these two States, for going ahead with Polavaram Dam project. As a result the project will get bogged down in the courts resulting in undue delays and wasteful expenditure of thousands of Crores of Rupees of tax payers' money, like Vamsadhara Stage II and Jhanjhavathi Projects. The only way out, is to opt for the alternatives to the Dam, which do not cause submersions in these two States. Otherwise the Project will not only be endlessly delayed, but also provides a thriving ground for Left-Wing Extremism, with associated law & order problems and social unrest & hardships.

 

 Environmental Clearance for Polavaram Project was a Mockery

 

A.P. Government is now continuing with the construction of the Project Canals (started in 2005), after obtaining stay orders from A.P. High Court on NEAA Order quashing Environmental Clearance granted by MOEF in 2005.

 

The MoEF accorded Environmental Clearance to the Project proposal on 25-10-2005, even without statuary Forest Clearance and National Wildlife Board Clearance, within 15 days from the date of conducting the so called EPHs (10-10-2005) , 8 days from the date of receiving the proposal from APPCB (17-08-2005) and 6 days from the date of Expert Committee recommending Clearance subject to submission of certain information (19-08-2005). Probably this may be an unusual record for clearing a major project in such a short time, in the history of MOEF.

 

 The Environmental Clearance thus accorded in undue haste by MoEF to Polavaram Project, even before obtaining other statuary clearances required and without Risk Assessment and Disaster Management Plans, has no validity and cannot be treated as Environmental Clearance required as per the norms of EIA Notification.

 

What is more interesting is that Sri.A.Raja, who is alleged to have been deeply involved in 2-G Scam, was the Hon'ble Minister for Environment and Forests , GOI, in 2005 at the time of according Environmental Clearance to Polavaram Project.

 

Need to reconsider Alternative Design for Dam

 

 Instead of requesting the neighboring States for release of waters from their reservoirs, the A.P. State can meet the requirement of water for Agriculture and Drinking purposes for most parts of the State, by maximizing the utilization of Godavari Waters, at present being drained out into Bay of Bengal. This can be achieved at the earliest possible, only by opting for viable alternatives to Polavaram Dam Project, at present being pursued by the State Administration, avoiding submersion of Tribal areas in the States of Orissa and Chhattisgarh and reducing the submersion to the barest minimum in AP State.

 

The alternative design presented by Er. T. Hanumantha Rao, retired E-in-C of AP and an internationally acknowledged expert on irrigation, proposes low barrages at three places (downstream of Bhadrachalam across Godavari,& Sabari and at Polavaram), in place of a Dam & Reservoir at Polavaram, similar to the one existing at Dowleswaram.

 

 The alternative proposal is understood to cost less, while realizing all the benefits of the earlier (Dam) proposal and avoiding submersion of any villages in the neighboring States apart from saving large number of tribal villages with about two Lakh population in A P State. It also makes use of the Canal system and other works under construction at an expenditure of more than Rs 4,000 Crores already incurred..

 

It is requested that the proposal of Er.T.Hanumantha Rao, about which AP Government seem to be having certain reservations about its Technical feasibility and Cost aspects, be reviewed and assessed by an "Independent Team of Experts" to be appointed by Got of India, to facilitate  its early consideration / implementation.       

 

Conclusion

 

If we do not learn to move forward in harmony with Nature by observing the principles of Sustainable Development & Precautionary Approach, "the worst large scale destruction can be caused by man-made activities-Nuclear Power Plants and Major Dams".

 

The Nuclear Power& Major Dams are not just the Evils and they are the Devils. Evil of our own making can be overcome. The Devil cannot be overcome, not even if we ourselves conjure him into being. This is why; staking our future on Nuclear Power/ Major Dams is a Pact with the Devil, impacting the generations far into the future. 

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Time for Action & Results and not for Schemes & Announcements

 

It is heartening to note that the  Chief Minister of AP announcing a number of measures for the benefit of the tribal people on the occasion of World Tribal Day during his visit to Tribal Areas in Khammam district and the assurance of the Speaker of AP State Legislative Assembly regarding the rites of Tribal People  on Forest Lands and the follow up action on  Araku Declaration for overall wellbeing of the Tribal People.

 

30 Years of inaction

 

 This is to bring to the kind notice of the  Chief Minister and the  Speaker, the fate of  the 10 Tribal Families of Patwarigudem (V)  Dammapeta(M), Khammam Dt. who were deprived of their Patta Lands for inclusion in the Forest Block Lachapur Extn.I, Dammapeta Range of Khammam Forest Division as far back as February 1983. Unfortunately till today, they  have  not been provided with the alternate Patta Land ordered for the  purpose. There is no response and follow up action  on letter dated 23-02-2010 addressed to  the  District Collector, Khammam and letter dated 27-05-2010 addressed to  the Chief Minister

 

 In spite of bringing the matter to the notice of various agencies/authorities concerned during the last 2 years, the matter which is outstanding for about 30 years, remains unsolved and rests with the Tahasildar, Dammapeta Mandal, while the District and State Administrations  become helpless onlookers.

 

 Conclusion

 

The painful conclusion is that the Delivery Systems at the Grass Roots level are indifferent/ insensitive, unresponsive and not made accountable and  there is no effective  Governance, leave alone Good-Governance, particularly at the District Levels.

 

With present state of Governance at the District levels and the Govt. policies of  diverting forest and tribal lands for Bauxite Mining , no useful purpose will be served by assurances and declarations to Tribals, except widening the credibility gap about the State Administration. 

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