Nuclear Power Park at Kowada, Srikakulam Dt. AP State --Sweeping and Evasive Comments of NPCIL

 The Nuclear Power Corporation of India Ltd (NPCIL), while responding to various Points raised with regard to the proposed Nuclear Power Park (6X1000 MWe, LWR) at Kowada village, Srikakulam, Dt. A.P. State, made some sweeping and evasive comments, which are discussed in the subsequent paragraphs

 

1) Point: Nuclear Power is Not CO2 Free, Not Cheap, Not safe, Not Clean & Green and Does not Provide Energy Security.

 

NPCIL Response: "The role of Nuclear Power is clearly defined in The Integrated Energy Policy of India 2005" -----"This is a well known fact in public domain in the world that Nuclear Power (NP) is proven to be Environmental Friendly, CO2 Free, and is able to meet the huge demand of power by ever increasing development activities and population and this demand cannot be satisfied by other non-conventional sources of energy due to their low production potential per unit area and their dependence on vagaries of nature. This is being proved by the increasing number of NPPs all over the world and many nations opting for nuclear energy in future. Therefore the available option is to develop NPPs for the progress of the Nation"

 

Observation: NPCIL seems to be taking shelter under "The Integrated Energy Policy of India 2005"   without addressing specific points raised & by making sweeping &evasive comments as explained below:

 

a) CO2 Free- The fact is, "It takes energy to make energy"- even Nuclear Energy.   Although Nuclear Power Plant itself releases no CO2, the entire Nuclear fuel Cycle ,- from Uranium mining  to decommissioning & dismantling of the Reactor and the safe storage of radioactive nuclear waste generated in the process - is the most complex and the intensive user of Fossil Fuel. In the huge campaign now being run all over the world, to present Nuclear Power as CO 2 Free, the Nuclear Industry is suppressing the fact that it is a guzzler of fossil-fuel, the kind of energy the

Nuclear power is touted as replacing -with the concurrent production of CO2. . We get six times the reductions in CO 2 by investing in Energy-Efficiency, rather than Nuclear Power and much faster too.

b) Environment Friendly-As per the Environment (Protection) Act 1986, the "Environment" includes Water, Air & Land and the inter-relationship which exists among & between them and human beings & other living creatures, plants, micro-organism & property. The Nuclear Power, producing nuclear waste with high levels of radiation and not to talk of accidents, having serious adverse impact on living organisms, cannot be termed Environment Friendly by any stretch of imagination. The Electricity is but the fleeting byproduct and the actual product is forever deadly radioactive waste, which needs to be isolated from the biosphere for thousands of years that defy human imagination. Even 21 st Century science has no answer for safe disposal of Nuclear Waste.

c) Clean and  Green Energy-Nuclear Power cannot be termed as renewable source of energy because its fuel materials are as limited as fossil fuels such as Coal, Oil, etc The head of the International Renewable Energy Agency –- an intergovernmental group known as IRENA that advises about 140 member countries on making the transition to Clean Energy –- dismissed the notion of including Nuclear Power among its favored technologies. The IRENA will not support nuclear energy programs because it is a complicated process; it produces radioactive waste and is relatively risky.

 

d) Increasing Number of NPPs & many Nations opting for Nuclear Energy-Why hasn't USA commissioned even a single Nuclear Power Plant (NPP), after 1974? Why has Austria opted out of Nuclear Power as a solution for problems of Climate Change or Peak Oil Crisis? .Why has Germany opted to phase out Nuclear Power Plants by 2022? Why has Italy voted against Nuclear Power in the Referendum?  Why has Switzerland dropped the proposal for new NPPs? Even China and Japan are reported to be revising their Nuclear Power Policy after the recent melt down of Fukushima Dai-ichi NPP in Japan. In March 2007, on the 50 th Birthday of the Euratom Treaty, why have more than 600,000 Europeans and 800 European Organizations demanded that European leaders phase out Nuclear Power and massive investments in Energy Saving,/ Efficiency and Renewable Energy ? Why is Indian Government (DAE) being blind to the realities and obstinate about NPPs?

 

e)To Meet Huge Demand of Power for Increasing Developmental Activities-Based on an unrealistic assumption that economic vitality requires steadily increasing energy consumption, the total capacity of 8, 00,000 MW is projected by 2031-32, which is about 5 times the present capacity.   The breeding ground for Nuclear Power is the inflated power demand projections. As a result, total Nuclear Power capacity projected is 60,000 MW by 2031-32, which works out to be hardly 10 % of the total projected capacity. The Nation's Energy Security depends on efficient use of Energy Services that maximize economic competitiveness and minimize environmental degradation / impact.

2) Point: Safe Disposal of  Radio-Active Waste

NPCIL Response: At present the low & intermediate radio-active solid/solidified wastes are stored in Near Surface Disposal Facility (NSDF). They are stored under ground at a depth of maximum up to 4m either in trenches / RCC vaults / Tile holes depending upon the surface dose rate of the waste. The solid waste disposal site is fenced and designed to store waste for an active control (monitoring, surveillance, remedial work) period of 100 years followed by passive control (land use control) period of 200 years. After 300 years of storage (with 10 or more half lives) the total radio activity of the material will be almost negligible.----- The stored solid waste will never come in contact with ground water during its operational life.

Observation: NPCIL talks of storage of low and intermediate level radioactive solid /solidified wastes generated by the reactor, without addressing the main concern of storage/disposal of high level and extremely potent radioactive wastes generated during the operation of the Reactors and after their decommissioning & dismantling. This is clear indication of misleading the public, on the part of NPCIL.

Each 1000 MW NPP generates 1500 tons of extremely potent radio-active waste in its operational cycle of 50 years. Even though NPPs have been operational for nearly 50 years, the Nuclear Industry has yet to determine how safely transport, this deadly material, prepare adequate storage facility, and to supervise and guard the site for  periods of time, almost beyond our comprehension – 240,000 years. In addition huge quantities of intensely radio-active wastes from decommissioning and dismantling NPPs are to be catered for after the operational cycle of 50 to 60 years The Depleted Uranium (DE) 238, the discarded material after enrichment of Uranium 235, which continues to be radio-active with half-life of 4.5 billion years, remains another problem

The key issues raised about the quantum and duration of radioactivity and solutions for safe disposal of high level and extremely potent radioactive nuclear waste remain unanswered. The questions about Costs, information, transparency, independent regulation, the involvement of the public at large and risk management arise.

3) Point:. Release of Substances Harmful to Human Health 

NPCIL Response: Tritium release in Light Water Reactors is insignificant .Provision for monitoring tritium will be provided    

Observation::Even accepting that Tritium release from Light Water Reactor (LWR) is insignificant, how effective the proposed monitoring and control measures would be, is not known. The information is required regarding the type LWRs being provided for Kowada Nuclear Power Park- Generation II or III?

The response conveniently ignores the possible risk for exposure to unhealthy amounts of radiation from other radioactive gases routinely released from the reactor and the consequences of possible accidents / meltdowns during operation, due to human / mechanical errors and likely terrorist attacks and impacts from climate change and natural disasters.  

4) Point: Hazardous Radio-active Releases- Risk to Health & Environment

NPCILResponse: "The NPP unit is so designed that activity releases to the environment through pre-designated release points. These radioactive effluent releases to the environment are continuously monitored and controlled.------The average dose to the members of the public from all exposure pathways will not exceed 1 mSv in a year by virtue of disposal of liquid, solid and gaseous waste to the environment as stipulated in AERB safety Manual. In the design stage various anticipated accidents and their combinations are assumed and suitable design is worked out on the basis of analysis of the accident scenario. Even very unlikely events are analyzed and mitigating measures are included in the design.-------"

Observation: As an exposure of 100 millisieverts (mSv) per year is considered the lowest level, at which an increase in cancer risk is evident, the claim of NPCIL of 1 mSv needs to be subjected to close and strict scrutiny. 

Contrary to NPCIL claims, NPPs are permitted routinely to emit hundreds of thousands of Curies of radioactive gases and other radioactive elements into the environment every year, with significant exposure to radiation, which may be beyond 100 mSv per year. A German study has shown that within a 10-mile radius of their Reactors, childhood leukemia has increased to a frightening level.

U.N. Secretary-General Ban Ki-Moon speaking at Kiev conference commemorating the explosion of a reactor at Ukraine's Chernobyl nuclear reactor is reported to have said."To many, Nuclear Energy looks to be a relatively clean and logical choice in an era of increasing resource scarcity. Yet the record requires us to ask painful questions-: Have we correctly calculated its Risks and Costs? Are we doing all we can to keep the world's people safe?" "The unfortunate truth is that we are likely to see more such disasters."

Japan is perhaps the most technologically advanced nation on earth and yet, the review report by IAEA, of the Fukushima Nuclear Disaster, time after time finds missing measures It highlights the fundamental inability for anyone to anticipate all future events and so deeply undermines the claims of the nuclear industry and its supporters that this time, with the new generation of reactors, things will be different.

Japan has a well organized emergency preparedness and response system and dedicated and devoted officials and workers. But complicated structures and organizations can result in delays in urgent decision making. Even in one of the best nuclear safety regimes, the complexity of accidents can overwhelm the emergency response.

To sum up, NPPs are designed and built mainly for controlling the nuclear fury of the known and anticipated events  at its heart for half a century or more, and controlling the waste produced lasting for many thousands of years,  remains unresolved and beyond the mankind comprehension. On those timescales, unforeseen events are a certainty, with disastrous and very expensive consequences..  

5) Point-.Public Consultation

NPCIL Response: As part of Public Consultation process NPCIL has facilitated the visit teams of persons from the proposed project area, journalists etc to other NPPs like Tarapur, Kalpakkam, Kudankulam etc .Interaction with the project affected people of the areas have also taken place as part of the consultation process..

 Observation: The claim of NPCIL facilitating the visit of teams to other NPPs seems to be window dressing and brain washing exercise. .One side claims are made that radiation from NPP is very low and no adverse impact on the environment, while the actual facts and ground realities are not being shared with the public. The land acquisition for the project should not be started, unless the apprehensions about the possible release of radiation during normal operation of NPP and in the event of likely accidents and their adverse impacts on humans, biodiversity and environment, are cleared, particularly in the light  of recent Fukushima NPP disaster in Japan . 

6) Point:. Public Apprehensions on EIA Process

NPCIL Response: EIA Report is prepared based on precise & accurate information / data collected.----  The project will have an effective environmental management plan which ensures no adverse impact on agriculture, cattle and environment around the project.---"

Observation: We have the bitter experience of EIA Reports and EPHs in respect of Uranium Mining Projects of UCIL in Nallagonda and Kadapa districts in AP State. Even Mr. Jairam Ramesh , Hon'ble Minister for E&F is reported to have stated recently that "EIA Reports are a Joke" Any talk of "Corporate Social Responsibility" of NPCIL makes no sense unless it is demonstrated in EIA Reports by addressing various points raised about NPPs and by well  informed public participation in  Environmental Public Hearing  for the proposed NPP  

7).Point: Nuclear Establishment & AERB

NPCIL Response: NPCIL, and HPD, BARC are totally independent establishments under Department of Atomic Energy (DAE)------ AERB functions effectively and exercises its authority in an independent manner.

Observation: The hollowness of NPCIL response can be seen form the following::

". I can personally vouch from my earlier experience as chairman, AERB that the DAE and the AERB often work in collusion, misusing the Official Secrets Act much more to cover up the serious lapses and inactions in their operations than to protect the safety or security of the public. As per AERB's constitution, the AERB chairman is answerable to the AEC and he cannot therefore disobey the orders of the chairman, AEC (who is also concurrently the Secretary, DAE). Thus, there is no independent nuclear safety regulation in the country and the AERB merely serves as a lapdog of the AEC, DAE and the Prime Minister's Office (PMO)"----Dr. A Gopalakrishnan, 03 May 2010/ New Indian Express

"While India has a good regulatory body, there is need for more transparency," advised director-general of the International Atomic Energy Agency (IAEA) Yukiya Amano when asked about his reaction to massive protests against the development of the world's largest nuclear power hub at Jaitapur, Maharashtra

8) Point:. Exclusive, Sterilized &Emergency Zones of NPP 

NPCIL Response: Very general and evasive

Observation: As per information available, about 17,800 households with habitants of about 75, 000,in about 110 villages/habitats, covering an area  of about 26,700 acres  of private lands with agricultural activities, are reported to be in  these three zones . 

The adverse impacts of exposure to radiation from radioactive gases routinely released from the NPP and the consequences of possible accidents/meltdowns during operation and due to human / mechanical errors and likely terrorist attacks and impacts from climate change and natural disasters on this area have to be clearly spelt out and informed to the public, before the EPH is held

 9) Point: Alternative Choices

The NPCIL had conveniently chosen to be silent with regard to considering alternatives to the proposed Nuclear Power Park. During the EIA Process of the project the fundamental questions to be asked are:

       

a)    Is the proposed NP Project required for providing energy security?

 

b)    Are there viable alternatives which could provide the same benefits?

 

c)    What are the Life Cycle Costs  when compared to likely alternatives ?

 

d)    What is the level of public safety in relation to hazardous technologies?

 

 

Viable Alternative

 

  it is worth considering for adequate investments in Supply Side Management (SSM) & Demand Side Management (DSM) measures, as "Energy Conservation" is the fastest & the cheapest way of making available Clean Energy. As the energy conservation potential, in our energy intensive economy, is estimated to be more than 25%, we can easily do away with the projected 60,000 MW Nuclear Power. by 2031-32, which works out to be less than 10%

Precautionary principle

The "Precautionary Principle" states that if an action or policy has a suspected risk of causing harm to the public / 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.- "Proof of Burden on Polluter". The principle implies that there is a social responsibility to protect the public from exposure to harm, when scientific investigation has found a plausible risk.

 The U.N.Secretary -General Ban Ki-Moon, speaking at Kiev, commemorating the explosion of a Reactor at Ukraine's Chernobyl NPP 25 years ago. said "The more complex technologies become, the more complex societies become, the more important it is to involve civil societies, to have democratic institutions, a free press,"  

Let there be a free and frank public debate about the need for Nuclear Power in India ?

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