Letter to NDMA on Kaiga Potential Disaster

*NDMA team inspects Kaiga Atomic Power Station* https://www.deccanherald.com/state/uttara-kannada-belagavi-city/ndma-team-inspects-kaiga-atomic-power-station-1144229.html

The recent approval for the addition of 2*700 MWe nuclear power reactors at
Kaiga APP has led to a lot of concern to the local population, and to those
in the state who have a modest understanding of nuclear power reactor
accidents, as reported from Chernobyl and Fukushima. My representation
dated 23rd Dec. 2018 to Atomic Energy Commission, as forwarded below,
should emphasise multiple concerns to our people on safety issues, which
can be associated with the uncontrolled radiation leakage, along with many
other issues of importance to the entire country.

Having gone through that EIA report (Environmental Impact Assessment
report) of the proposal on Kaiga APP extension (Units 5 & 6), and having
made both the written as well as oral submission at the associated public
hearing, I notice that there are many serious concerns to the local
stakeholders, as well as for the state and the country as a whole from the
proposed project.

My principal concern has been that; whereas 4 nuclear reactors at Kaiga APP
have been operating since the last few years, the addition of about 1.6
times the earlier capacity (an increase from about 840 MWe to 2,240 MWe
capacity) in the proposed expansion plan will basically mean an exponential
increase in "risk" associated with a nuclear reactor accident, the quantum
of nuclear radiation leakage even in a normal operating condition, and the
quantum of nuclear waste, including the spent nuclear fuels, which will be
stored on the site.

Whereas, there have been a number of concerns with the statements made in
the EIA report, as prepared for the Project proponent (NPCIL in the present
case), the same is found to be seriously deficient in not considering: (i)
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; (ii) policy and details associated with the safe disposal
and long term storage of spent nuclear fuel and nuclear waste materials.

A serious issue noticed during the associated public hearing was the
number of unanswered questions over the adequate preparedness on part of
the concerned local authorities during a credible 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). It has to
be emphasised here that none of the concerned authorities, including the
local district authorities and AERC, have cared to respond to the
associated concerns so far.

Hence, I am appealing to NDMA to consider every one of these concerns with
all the seriousness they deserve, and to provide effective assurance to all
the stakeholders about the adequacy/ efficacy of the safety precautions
taken in this regard.

I notice with a lot of concerns that: whereas, the project proponent,
through EIA, seem to have shifted the actual responsibility of off-site
emergency measures to the Deputy Commissioner (DC), 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 the overall context that the area around Kaiga APP is of difficult
hilly terrain and is thickly forested, 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 are 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 a sufficient number of vehicles been 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?

If the difficult hilly terrain and thickly forested areas around Kaiga APP,
along with a number of rivers and streams, are diligently considered, it
can be credibly stated that even with the best intentions/ efforts of
SDRF/NDRF, it will not be feasible to safely evacuate even 50% of the
32,000 odd people of the area in the case of a major nuclear accident.
Hence, a major catastrophe for the welfare of the local population cannot
be credibly ruled out.

In this context of a credible and major catastrophe, the words
"pro-active" and "prevention" in NDMA vision should indicate that there is
a critical need to take all the associated issues into proper perspective,
and arrive at rational conclusions.

In the engineering management parlance, the term "risk" can be defined as
the product of "the probability of an incident/ event happening" and "cost/
implications of such an incident/ event". In the case of nuclear power
reactors, whereas the nuclear power industry maintains that the "probability
of an incident/ event happening" is very low, the "cost/ implications of
such an incident/ event" can be humongous, as experienced in nuclear
disasters at Chernobyl and Fukushima. Hence, the most innocent question
that can be raised in this context is: whether a nuclear power plant, which
is credibly associated with not inconsiderable "risk" is essential to our
society; certainly in the Indian scenario and even after witnessing
multiple nuclear accidents/ incidents including two nuclear disasters at
Chernobyl and Fukushima.

If certain analysis tools such as 'risk analysis'; 'costs - benefits
analysis'; 'SWOT analysis' etc. are diligently deployed as economic
decision making tools, the true costs to our country from a nuclear power
plant, as opposed to meager benefits will emerge unambiguously. Whereas
the benefit from a nuclear power plant can be a few million units of annual
electrical energy, the overall costs to the local communities and to the
country as a whole can be humongous: huge capital cost, environmental and
health costs, direct & indirect costs associated with any unfortunate
nuclear accident, costs associated with the long term storage of nuclear
wastes, costs associated with nuclear mines and nuclear ore processing
activities etc. As per many credible global estimates, and as per the high
level estimates available in the public domain for the proposed Jaitapur
Nuclear Power plant in Maharastra, the capital cost of a nuclear power
plant can be many times more than the cost of a comparable size power plant
based on alternative technologies such as solar and wind power plants.
Since these technologies are also benign, people friendly,
and environmentally sustainable, there can be no credible reason as to why
these technologies should not be the preferred options to meet the
legitimate electricity demand of our people. Our country also has massive
potential in such renewable energytechnologies, and it is also an official
policy of the govt. to aim to be a global leader in harnessing these
technologies. It is deplorable, henec, that there has been no credible
official policy document so far from our authorities, to clarify why the
nuclear power plants are continued to be built in different parts of the
country despite the associated massive costs and risks to the true welfare
of our people.

It must also be highlighted in this context, that the total nuclear power
capacity in the country is less than 2% of the total power capacity in the
country, and will only become increasingly irrelevant from the operational
perspective of the power sector due to the fact that massive additions are
being planned in other power technology sources, such as solar and wind
power plants, in the next 10-15 years.

In this larger context, my detailed representation dated, 12th September
2019 addressed to the PM (as in the PDF file attached) has
detailed discussions on various associated concerns, and on the vrey
relevance of nuclear power to our country. A diligent consideration of all
the associated concerns should be able to convince NDMA to urgenty
undertake a thorough review of the credible "risk" and massive costs
associated with nuclear power reactors for the country in general, and with
the proposed capacity expansion plan at Kaiga APP in particular.

I am of the considered opinion that in a densely populated and resource
constrained country of ours, NDMA has a much larger and critical role to
honestly try to avoid large scale disasters (certainly the avoidable
technology related disasters such as nuclear reactor accidents), and that
NDMA should not restrict itself just to undertake post-disaster relief
operations. Keeping in proper perspective all these risks, costs and
concerns to our people, it can be credibly stated that the best option to
prevent any associated disaster scenario from a nuclear power plant is to
avoid building a nuclear power plant in the first place. Since there are
many benign and attractive technological options to meet the
electricity needs of our people, NDMA should seriously consider
recommending to the Union govt. not to build additional nuclear power
reactors until all the available alternatives are fully harnessed in the
country; and also to safely decommission all the operating nuclear power
reactors in order to prevent the humongous costs and concerns of any
unfortunate nuclear reactor disaster to our people.

May I request that due diligence in this larger context is undertaken by
NDMA at an early date, and the necessary advice is made to the Union govt.
accordingly?

Regards
Shankar Sharma
Power & Climate Policy Analyst
Letter to PM in pdf subdirectory
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