On Koodankulam Nuclear Power Project – Questions, Questions, No Answers

November 24, 2011

by S. P. Udayakumar

When the Central Government’s Expert Group and the Tamil Nadu Team met for the first time on November 8, 2011, our representatives asked for the following documents with regards to the Koodankulam Nuclear Power Project (KKNPP): the Environmental Impact Assessment (EIA), Site Evaluation Study, Safety Analysis Report, VVER Performance Report and all other relevant documents for reactors 1 and 2.

When the Central and State teams met again on November 18, 2011, we asked for another set of documents:
· Detailed Project Report (DPR) submitted to the MoEF with annexures (including maps) if any in respect of reactors 1 and 2;
· The completed application in the format prescribed in the EIA notification with the annexures (including maps) seeking EIA clearance in respect of both reactors;
· Reports/Comments from the Tamil Nadu Pollution Control Board (TNPCB), including minutes of the public hearing in respect of both reactors;
· Application with annexures to the TNPCB seeking NOC /Consent under Air and Water Act along with the Consent orders of both reactors; Stop Work Notice and other show cause notices if any issued by TNPCB along with replies to the same;
· Reports/Comments from the Regional Office of the MoEF of both reactors;
· Reports /Comments obtained from any other government or expert agency such as port authorities, fisheries, coastguard, navy etc. of both reactors;
· All minutes (including draft minutes) of all the meetings of the Expert Appraisal Committee (EAC) of the MoEF of both reactors;
· Any supplementary or additional reports/studies submitted to MoEF pursuant to any queries of the EAC of both reactors;
· All studies/reports sub contracted to other agencies for the preparation of the EIA report (example Social Impact, impact on flora and fauna etc) of both reactors;
· Reports along with maps obtained from NIOT or other agencies for the CRZ clearance of both reactors;
· Application with annexures for CRZ clearance if any of both reactors;
· Minutes (including draft minutes) of EAC of MoEF for CRZ of both reactors;
· Request for inspection of all files with the MoEF in respect of both reactors.

We also requested the Central team to probe all the following issues and prepare position papers on each of the following 49 topics:
· siting of reactors 1 and 2;
· environmental impact assessment (EIA) report;
· Coastal Regulation Zone (CRZ) violations;
· public hearing processes;
· construction quality and reliability;
· contractor irregularities and corruption charges;
· employment issues;
· VVER reactor design and engineering;
· VVER reactor performance and safety;
· dummy fuel and disposal;
· fuel procurement for KKNPP and mode of transportation;
· fresh water demand and supply;
· Pechiparai dam and Tamirabharani river water utilization;
· desalination plants and reliability;
· impact of desalination on the sea and sea food;
· nuclear waste disposal and management (high-grade, medium-grade, low-grade and liquid wastes);
· reprocessing plans and plant at KKNPP site;
· radiation safety;
· routine emissions;
· workers’ safety and well-being;
· people’s safety and well-being;
· baseline data on health concerns;
· radiation illnesses (including all types of cancers);
· high and dense population around the plant (exclusion, sterilization and emergency planning zones);
· oceanography;
· fisheries and seafood security;
· impact on land, agriculture, livestock, and food security;
· impact on flora and fauna;
· coolant water disposal and thermal ecology;
· seismology;
· conservation issues (Gulf of Mannar biosphere and the Western Ghats);
· terrorist and security threats;
· impact on bilateral relations with Sri Lanka, Maldives, China and Pakistan;
· impact of mining activities;
· disaster management plans and emergency preparedness;
· evacuation procedure and preparedness;
· Russian and Indian liability issues;
· project cost and Russian debt analysis;
· electricity generation and transmission;
· capacity factor monitoring;
· fuel and waste transportation;
· decommissioning plans, technology and cost;
· impact of increased sea patrol and militarization of the area;
· erosion of civil liberties;
· noise pollution;
· KKNPP expansion plans (3, 4, 5, 6);
· IAEA safeguards arrangements;
· NSG-related issues;
· setting up possible weapons facility at KKNPP; and
· Any other related issues.

We asked for translation of these position papers into Tamil, Malayalam and Hindi languages to be disseminated widely throughout Tamil Nadu, Kerala and other states of India and to facilitate popular discussions, expert debates, media discourses, and dialogues with the governmental authorities and civil society groups.

Our demanding the above reports and studies was called into question almost immediately. In a TV debate, an assistant of Dr. Abdul Kalam, wondered who prepared the list of 49 topics for us and hinted that we did not have the capability of preparing such a list. Some of the Central team experts have even doubted the actual intention of asking for the above reports and information.

It is understandable why some politicians and bureaucrats doubt our intent because they always engage in underhand dealings with foreigners (Russia, France, United States, South Korea, Australia and so forth). We have asked for the above reports and studies in order to prepare ourselves for the ongoing negotiations and to initiate a meaningful dialogue with the Central and State teams.

Out of the 49 areas that we identified and asked for position papers, the “Presentation” of the Expert Group is completely silent on four: bilateral issues with Sri Lanka, Maldives, China and Pakistan; Russian and Indian liability issue; NSG related issues; setting up a weapon facility at Koodankulam.

[1] The Russian liability is a very relevant and important topic. The Indian and Russian governments signed an Inter-Governmental Agreement (IGA) in 2008 and Clause 13 states very clearly that the Russian government would not be held liable for any accident at the Koodankulam site. The Hindu newspaper leaked this IGA a few months back. Having put foreign corporations’ interests ahead of the Indian citizens’ interests, the Indian government does not share the IGA with the public or the press. Neither does it take a clear and open stand on liability with respect to the Koodankulam project.

[2] Siting of reactors 1 and 2 is a major issue that the Indian government and the Department of Atomic Energy (DAE) try to sweep it under the carpet. The “Presentation” talks about the application process but is silent about the exact spots chosen by the Russians, the Indian scientists’ and engineers’ unilateral shifting of those spots, the Russians’ objections and walk out, and the final “amicable” settlement. The “areas of significance” that contribute to the siting include effects of the plant on the environment such as “dispersion of radioactive/toxic liquid and gaseous effluents, the impact of radiation exposures to public during Normal Operation and Postulated Accident conditions taking into account dispersion patterns, population distribution, public water supply, milk and food consumption.” The “Presentation” further asserts that “ESL [Environmental Survey Lab] caries out the radiation monitoring” in the 16 km emergency planning zone.

[3] Environmental impact assessment (EIA) report: Environmental clearance was obtained for KKNPP 1 and 2 some 22 years ago on May 9, 1989. The KKNPP authorities claim that there is no need for a public hearing or fresh environmental clearances as the Ministry of Environment and Forest (MoEF) has confirmed. NPCIL is said to have done a Rapid EIA in 2001 and a comprehensive EIA in 2003. After all, the Expert Group has coaxed the DAE to put the EIA report on the NPCIL website: http://www.npcil.nic.in/pdf/Comprehensive_EIA_of_KKNPP1_2.pdf

[4] According to the “Presentation,” the Site Evaluation Report and the Safety Analysis Report are documents “that have been made available to AERB which is the statutory body authorized to accept and review these documents.” The “Presentation” does not say if we will get a copy of these reports or not.

[5] The “Presentation” establishes clearly that the KKNPP reactors 1 & 2 have been constructed “within 500 Mtrs from HTL” (High Tide Line) in gross violation of the Coastal Regulation Zone (CRZ) stipulations.

[6] KKNPP 1 & 2 are VVER 1000-V412 model reactors that do not exist anywhere else in the world. On the one hand, everybody in DAE and Government of India claims that the plants are absolutely safe. But the “Presentation” lists problems such as Design Basis Events (DBEs) that include “break of main coolant pipe” (loss of coolant accident, LOCA); Beyond Design Basis Events (BDBE) that include complete loss of power supply (station black out, SBO), multiple failure such as simultaneous occurrence of LOCA and SBO; postulated failure of control rods (Anticipated Transient Without Scram, ATWS); other postulated severe accidents; external hazards etc.

[7] The plant water requirement of KKNPP is 5664 m3/day and the potable water requirement is 1272 m3/day; so the total requirement is 6936 m3/day. Installed desalination capacity is 7680 m3/day (2560 x 3 units)and there is an additional unit of 2560 m3/day as a standby. The brine reject (350 m3/hour) is mixed with condensed cooling water discharges (2,50,000 m3/hour), diluted and released into the sea through the existing outfall channel. A baseline environmental assessment and mathematical modeling study on flow, dispersion of brine reject and extent of mixing in the sea is done. The “Presentation” asserts that the “brine reject will not have any impact in the marine environment while joining the sea.” It is also silent on the impact of desalination on the sea food, or the desalination plants’ reliability.

[8] The desalination plants are designed for “sufficient capacity” and hence water utilization from other sources such as Pechiparai dam and Tamirabharani river “does not arise.” But Dr. Abdul Kalam hinted recently in his 10-point plan that Pechiparai water could be brought to Koodankulam. Many KKNPP officials have also talked about taking Pechiparai water before. It is also not explained why underground pipes have been put in place around Kanyakumari district.

[9] As regards nuclear waste disposal and management (high-grade, medium-grade, low-grade and liquid wastes), the “Presentation” asserts that “Spent Fuel is not a waste in the Indian Nuclear Programme” as we follow a closed fuel cycle, “where the valuable fissile materials like Uranium and Plutonium which are present in the Spent Fuel are recovered for reuse.” So, “spent fuel is therefore an asset that needs to be preserved.” At KKNPP, Spent Fuel from the reactors “will be carefully stored in Storage Pools” that are high-integrity concrete pools with additional stainless steel sheet lining. The DAE “has long experience and expertise of a high order in the safe management of Spent Fuel.” But please do not ask for any quantification. Nobody will ever give that.

The Spent Fuel is going to be transported “through both Railways and by roadways” to a Reprocessing facility (God knows where) “in a safe manner without any public hazard.” Do not worry; “[a]dequate technology and years of experience are available” with DAE. When we met with the Prime Minister on October 7, 2011, Dr. S. K. Jain said there would be some waste that could be melted into a glass ball. Mr. Kasinath Balaji, the director of KKNPP, claimed a few days later that there would be “some waste” and it would be kept in the Koodankulam plant and reprocessed. Dr. Abdul Kalam asserted later that week that there would be 25 percent of waste. So we heard three versions in two weeks’ time. No one speaks like a scientist and gives any clear and concise quantification.

[10] The “Presentation” claims that “[n]o radioactivity release through the sea water cooling is possible” not because there will be no radioactivity but because “this loop is physically separated by three levels from the coolant loop which enters the reactor.” The “Presentation” does acknowledge that “some low and medium level waste would be generated in the station which is treated inside the plant. Very low level effluents from these would be generated.” But there is hardly any more concrete information about this important issue and the report simply says “there are norms and limits for their releases.” Gaseous routine emissions will be there and they are “filtered in High Efficiency Particulate Air (HEPA) and Activated Charcoal filters before discharge to the Stack.”

According to the report, the “authorized limit of low level effluents through air and water from KKNPP is restricted” and “it will not lead to more than around 4.36 percent of the dose limit for the public recommended by ICRP (1mSv). The limits of concentrations in aquatic and atmospheric releases are fixed in such a way that “the dose will never exceed the authorized limits” and the concentrations of discharges through stack are monitored continuously. The “Presentation” also says that the “activity levels of liquid discharge are monitored daily to ensure this.” Moreover, the environmental survey program of the ESL will assess the impact on the flora and fauna and in estimating the dose to members of the public. ESL is said to be monitoring the environment around the plant and has been collecting and analyzing samples of water, air, soil, flora and fauna from 2003, which forms the baseline data. The report says “[t]his activity will be continued throughout the entire lifetime of the Plant and records maintained.”

The “Presentation” says: “we feel that the radiation safety of the people around KKNPP is guaranteed and there would be no impact of the operation of the power station on the public.” Although people in the high background radiation areas of Kerala are exposed to more than 10 times the natural radiation, “no deleterious effect could be noticed” among them. The report further claims “no genetic effects even amongst the progenies of the Hiroshima Nagasaki atomic bomb victims.” The report questions: “When this is the fact how a small percent (1%) of the natural radiation does that might be received around nuclear power stations lead to any genetic effect or cancer incidence?” The report concludes: “The fear about genetic effects of radiation around nuclear sites is more psychological and is contrary to scientific facts.”

The report talks about collecting baseline data on health concerns. If the health concern is only “psychological” why should we “evaluate the impact due to the operation of the station later”? The report concludes that “investigations show that only certain type of cancers notably that of thyroid is due to the effect of radiation.” Dr. Shantha, a member of the Expert Group, has said that there is no connection between radiation and cancer (Dinamalar, November 19, 2011).

[11] The report lists the following population:

Distance Population Reality
0-2 km 0 450 families live in the Casa Nagar
2-5 km 23,960 40,000
5-16 km 94,733 (1.2 million people in 30 km radius)

[12] The safe grade elevation of KKNPP site is 7.5 m above MSL and a shore protection bund is constructed along the shore to a height of 8 m to MSL. It is pertinent to note the tsunami waves of December 26, 2004 reached the top of Thiruvalluvar statue that is 133 feet high.

[13] According to the report, “the lethal temperature of fin & shell fishes was found to be between 38.2 and 43.2 C.” The maximum possible surface sea water temperature of Koodankulam areas is 29 C during summer months and the temperature rise is stipulated by MoEF as 7 C. The maximum temperature at discharge point will be 36 C which may not harm any fish. The report asserts that “fish, being a cold blooded animal, it can adjust the body temperature with that of environment within the sub lethal temperature and a rise in body temperature will enhance all biological activities, including growth and production.” The report also establishes that “the fish and prawns will have the capacity to sense the change in temperature in ambient water and try to avoid and move away from the adverse condition, if any, from the point of discharge.” Although the report claims that Tarapur and Kalpakkam plants have not “shown any adverse effects on Marine life including the fish.”

[14] The “Presentation” claims that “there will not be any impact on the land environment as discharges are insignificant.” According to the EIA, the land use classification in 30 kms radius of the plant site based on satellite mapping. The land use/land cover classification indicates 8.73% area covered by vegetation, 8.73% are covered by barren land, 23.39% are covered by scrubland, 8.52% area covered by sandy area, 0.08% built-up area, 49.68% water body including sea, river etc.

[15] KKNPP is located in Indian Seismic Zone II, the least seismic potential region. The “Presentation” also claims that the most intense earthquake experienced in the 300km region is the one that occurred at Coimbatore on 08/02/1900 (6.0 in the Richter scale). There have been quite a few significant tremors in the Koodankulam area. On February 9, 2003 at 9:45 pm there was a tremor at Palayankottai. On March 19, 2006 at 6:50 pm there were tremors at several villages around Koodankulam such as Kannankulam, Anjugramam, Azhagappapuram, Mylaudi, Swamithoppu etc. On March 21, 2006 at 1:30 am and 5:00 am there were tremors in Karur district. In August 2011 there were tremors in 7 districts of Tamil Nadu. On November 19, 2011 at 4:10 pm, there was an earthquake south of Kanyakumari that measured 5.2 on the Richter scale.

[16] The “Presentation” claims that the “emergency exercise including the off-site emergency exercise that may require evacuation of a section of the population, are carried out accordingly.” In fact, no such exercise has been done so far. It is claimed that “emergency plan for actions to be taken in public domain during any off-site emergency were prepared and provided to District Authorities.” It is not clear when and what was done.

Emergency procedures are included in “Emergency Preparedness Plans” Vol-1 and Vol-2 documents. The KKNPP plants are tested periodically by conduct of emergence exercises such that any deficiency can be observed and corrected. Plant emergency exercise is conducted once in 3 months, site emergency is conducted once in a year, and the off-site emergency is conducted once in two years. A detailed training program was conducted by the District Collector for the officials from Revenue, Social Welfare, Fire, Health, Agriculture, Fisheries, Irrigation, Forest, Animal Husbandry, Electricity Board, Transport, Local Administration and police departments.

[17] The sanctioned cost of the KKNPP 1 & 2 is Rs. 13,171 crores including interest during construction. About half of the cost is financed by Russia and it has to be repaid in 14 annual installments after the commissioning of the plant. The report claims that the “set back in project completion schedule has resulted in revision of the cost estimates.”

[18] The decommissioning cost is met by a levy of 2 paise per Kwh charged along with tariff to create a corpus. This levy is reviewed periodically to meet the fund requirements and revised. Some of the Indian NPPs have undergone significant renovation and modernization activities including replacement of components like pressure tubes and fittings, feeder pipes etc. This experience has demonstrated that “technology for such dismantlement activities, that are similar to decommissioning, is available in the country.” The radioactive waste arising from decommissioning is not significantly different from normal operation although its volume will be comparatively large. According to the report, “In India we have good experience in handling and disposal of such waste.”

In the final analysis, this “Presentation” is hardly scientific and does not tell anything concrete or useful. This wishy-washy report does not allay the fears and concerns of the people; in fact, it aggravates the people’s fears by hiding all the vital information about the KKNPP project. The PMANE expert team that is going to meet on November 27, 2011 in Chennai will respond to this “Presentation” officially.