Comment by Advocate G. Sunderrajan, representing the People’s Movement in the Supreme Court, on NPCIL’s emergency plan in Koodankulam:

1. While safety and quality assurance in the selection of material, design and layout of plant, site selection etc are important in identifying a site and design that minimises the chances, risk and impact of any potential accident or event, it is the robustness of the emergency plan and the preparedness of the disaster management system and local population that is key to determining the impact of any nuclear accident. In other words, in addition to a well-developed emergency handling plan important, it is imperative that various individuals, including nuclear plant personnel district administration officials, NGO and civil society actors, and local residents are well informed and trained in responding to warnings and instructions in the unlikely event of nuclear accident. It is my humble submission that the 3rd Respondent NPCIL, and the Tirunelveli district administration are woefully ill-prepared, both in terms of training and infrastructure, to handle an offsite emergency. It is also my submission that the people living in the vicinity of the nuclear power plant have been kept in the dark about how to react during an emergency, and the sole event organised purporting to be an off-site disaster management drill was a sham exercise. Leave alone residents of the target area for the drill, even the police personnel that participated in the drill were unclear about the nature of the exercise.

Related Documents:

NPCIL’s Koodankulam Offsite Emergency Preparedness Plan

AERB guidelines – emergencies 1

2. The Offsite Emergency Plan prepared by NPCIL along with the District Administration is designed for an Emergency Planning Zone of 16 km around the plant site. According to the population data provided in the Offsite Emergency Plan prepared by the 3rd Respondent, the population in the plan area of 16 km around the site is 2,59,237 people as per 2001 census data. This Emergency Plan itself is outdated, considering that it obtained its final endorsement – that of the District Collector of Tirunelveli – on 3.3.2011, exactly a week before the Fukushima disaster, and therefore was not informed by the lessons of that disaster. In the wake of the March 2011, Fukushima disaster, the Japanese authorities ordered mandatory evacuation within a 12 mile (19.3 km) radius of the plant. It recommended evacuation within 18 miles (29 km) of the plant, and actually evacuated people from places up to 25 miles (40 km) Northwest of the Fukushima Daiichi plant. All of the land within 12 miles (20 km) of the destroyed nuclear power plant, encompassing an area of about 230 square miles (600 sq km), and and additional 80 sq miles (200 sq km) located Northwest of the plant were declared too radioactive for human habitation. More than 159,000 people have been permanently evacuated, and the regions were declared permanent “exclusion” zones.

3. The Task Force set up by the AERB at the behest of the Prime Minister’s Office after Fukushima does not even review the adequacy of the Offsite Emergency Planning guidelines, which remain outdated and uninformed by more recent developments.

4. The experiences from Chernobyl too do not seem to have affected the safety culture of Indian nuclear establishments. For instance, the April 1986 Chernobyl disaster left behind a permanent exclusion zone of 18 miles (29 km) around the plant, and actual evacuations were carried out as far away as 100 miles (160 km) from the plant.

5. Learning from the Fukushima accident, Japan is now contemplating expanding its Emergency Planning Zone to 30 km.  In the US, the Nuclear Regulatory Commission is currently considering a proposal that will expand the Emergency Planning Zone to 25 miles (40 km) and an emergency evacuation zone of 50 miles (80 km). On 30.4.2012, the proposal for the above rules amendment was published on the US Government’s Federal Register.

6. It is submitted that the Offsite Emergency Plan is outdated and unsuitable to deal with radiological emergencies of the kind that can arise from a disaster at a 2000 Mwe nuclear complex. Radiological emergency planning needs to take into account wind directions and the ability of radiation plumes to travel hundreds or even thousands of kilometres. Fukushima disaster resulted in advisories against contaminated food and livestock as far away as 100 miles (160 km), while the Chernobyl disaster resulted in similar advisories banning contaminated food and livestock as far away as in Wales, more than a 1000 miles (1600 km) away. The traditional disaster planning template based around responses to chemical disasters such as the 1984 Bhopal Gas Disaster are justifiably restricted to a single district. Radiological disasters ought to consider the possibility of not merely trans-district effects, but even trans-State or transnational effect. The current emergency plan – inadequate as it is to even deal with a disaster that does not extend beyond Tirunelveli district boundaries – ignores the fact that Sri Lanka, Kanyakumari district, Thoothukudi district and Thiruvananthapuram district are within striking distance of any radiological emergency emanating from the plant. Nagercoil, which is slightly above 20 km from the plant is in a different district. Thiruvananthapuram district, including the Kerala state capital of the same name, is 56 km away as the crow flies. Between Koodankulam and Kerala lie the Western Ghats, which if contaminated by radioactive toxins will be disastrous to both Kerala and Tamil Nadu as the Ghats are the watersheds for the region. Sri Lanka’s metropolises are 213 kms away. A safety culture informed by abundant caution and attention to detail would necessitate the preparation of a plan for the neighbouring districts to react. But this has not even been thought of, as the entire exercise is merely seen as a paper-formality with cooked up numbers and recommendations for impossible feats of coordination based on non-existing infrastructure.

7. It is a known fact that emergencies happen when one least expects it, and one should be prepared for it from the moment that a nuclear plant is commissioned. In other words, emergency preparedness has to precede the commencement of actions that could potentially result in a disaster. Emergency preparedness is not merely the preparation of a paper plan. Rather, it involves regular training of personnel and public who may be required to act in the event of a disaster, the availability of infrastructure, supplies, medicines, medical facilities capable of handling the fallout of such disasters.

8. The AERB Safety Guide No. AERB/SG/O-6 issued in March 2000 deals with the “Preparedness of the operating organisation in handling emergencies at nuclear power plants.” Para 1.1.3 on Page 1 of this document categorically states that:

“Before the commencement of operation of an NPP the Operating Organisation shall ensure that the following requirements are met:
(i) The emergency response preparedness plans for NPP shall be drawn up and approval from appropriate competent authority obtained.
(ii) Necessary training shall be imparted to the personnel to be deployed in implementing the action plans.
(iii) The implementability of the plans shall be confirmed by conducting exercises. ”

9. It is humbly submitted that no training has been imparted to personnel, particularly those among the public authorities such as police, fire, health, fisheries, civil supplies, regional transportation etc to be deployed in implementing the action plans. The AERB Guide further requires that such trainings, especially for State Government officials, need to be conducted regularly and periodically in view of the possibility of their frequent transfers. (Para 8.2.1, page 24) The outdated and pre-Fukushima Offsite Emergency Plan submitted by NPCIL deals with the Medical Plan in Section 3.9. It mandates the training of medical and paramedical staff from all PHCs of Tirunelveli centres, with such trainings being coordinated in consultation with the Director, Medical and Health Services, Tamil Nadu. No such trainings targeting the PHC staff has been conducted. Beyond making periodic demands for the full share of power from the Centre, the Tamil Nadu state Government has done little to prepare its administration to handle the fallout of a radiological emergency. Moreover, the manual prescribes the various equipment and supplies that needs to be at hand at all the PHCs across the plan area. This requirement too is not met. The outdated and pre-Fukushima offsite emergency manual expects the PHCs to function as screening centres where seriously exposed persons will be identified for referral to base hospitals with specialists. It also expects such specialists to have been priorly identified and equipped with further training to handle patients exposed to radiation. The manual also expects transportation vehicles engaged in evacuation to be equipped with First Aid and a list of prescribed items specific to the task of handling radiological victims. None of these have been prepared for. If the plant were to be commissioned on December 15, 2012, as per the latest predictions of Shri. Narayanasamy, Minister of State for PMO, and a disaster were to occur soon thereafter, even if evacuation succeeds, the medical infrastructure would be unable to handle the patients because of lack of training and infrastructure.

10. The Offsite Emergency manual provides a list of rallying points, where evacuated people can be temporarily accommodated. All such points are either Government or private schools. Each school is listed as having capacity to accommodate between 15,000 and 35,000 people. For instance, the Government Higher Secondary School in Parappadi, Illangulam, is said to be able to accommodate 20,000 people; Sri Ramakrishna Higher Secondary School and Stella Maris Higher Secondary Schools in Thisayanvilai are said to be able to accommodate 25,000 each; and the Concordia Higher Secondary School and Salvation Army Higher Secondary School in Vallioor are said to accommodate 35,000 people each. This an egregious over-estimate. Most of these schools can accommodate less than a fourth of the stated number of people, unless the disaster management authorities intend to stuff people like sardines in a can, and even then problems of hygiene and sanitation would remain challenges. Further, most Government schools are notorious for their infrastructural problems. There is not sufficient water for students, and toilet facilities are poor to non-existent. It must be noted that the plant is coming up in an area that suffers from perennial water scarcity. The temporary accommodation of such a large concentration of people in such small places will create a new disaster arising from the unmanageable problems caused by lack of hygiene and sanitation infrastructure. The Emergency Preparedness manual cannot engage in wishful thinking and would have to be prepared very conservatively, if not realistically.

11. All the Rallying Points contemplated in the Offsite Emergency Preparedness plan are located between 25 and 30 km from the plant site. This itself may introduce fatal kinks in the implementation stage considering that these areas may themselves fall within the evacuation area given their proximity, and given what we know of the impact zone of such disasters from Chernobyl and Fukushima.

12. The casual nature of the Offsite Emergency Planning manual is manifest from the following:

a) Only a 16 km planning zone has been considered;
b) Transdistrict, trans-state or trans-national effects have not been considered
c) All rallying points are well within distances where the potential for serious exposure and contamination is very real and present in the event of a Level 7 accident.

The casual nature of the Offsite Emergency Planning manual is also probably a result of the failure of planning authorities to consider a Level 7 accident. NPCIL has admitted in response to an RTI query that a “Level 7 accident is not envisaged” and that it does not have an estimate of the maximum population that may be evacuated in the event of a Level 7 accident because such an accident has not been considered.

13. The manual states that all villages in the Emergency Planning Zone are connected by good roads. This is simply untrue, as there are many villages, and fishing villages in particular that are very inaccessible. The recent disaster involving fires and explosions in Sivakasi in September 2012 took nearly 40 lives and injured several hundreds. The death and injury toll was aggravated because of the delay in arrival of fire tenders and the delays in evacuation of injured people to safer places. These delays were in major part due to the poor condition of the roads. The complacent statement regarding the satisfactory condition of roads within the Emergency Planning Zone is another instance of wishful thinking that could have grave consequences in the event of a disaster.

14. Further, the Emergency Preparedness manual only contemplates road evacuation under conditions where the roads remain accessible. During the 2004 tsunami, it took more than two days to clear access and restore electricity to hundreds of villages even in well-administered villages like Cuddalore and Nagapattinam. In typical fashion, the planning authorities have worked under fatally flawed assumptions that a Level 7 Accident will not happen, and that any nuclear mishap that may occur will only be caused by human error, and not due to an extreme weather event like cyclones or tsunamis.

15. A bulk of the responsibility of offsite disaster management lies with the District Administration and the State Government. Given the hostile position taken by the District authorities and the State Government towards the people living in the vicinity of the plant, there have been no opportunities for awareness raising and preparing people to react appropriately in the event of a disaster. Indeed, over the last year, more than 300 cases have been filed against more than 150,000 people in connection with the protests against the nuclear plant. Such a vitiated atmosphere is not conducive for a serious engagement on the issue of emergency preparedness, and exposes the fact that no off-site exercises of any serious nature have been conducted as required by the AERB as a precondition to commencement of operations. The fact that AERB is prepared to grant permission to commission the plant without satisfying its own requirements of having in place a robust offsite emergency plan, a trained plan enactment machinery and informed public highlights the casual disregard for the well-being of people living in the vicinity of the plant.

16. It bears repeating that the emergency planning authorities, namely the 3rd Respondent and the State Government officials, have failed to take seriously the exercise of emergency preparedness. The National Disaster Management Authority, headed by the Prime Minister, has published a manual titled “Management of Nuclear and Radiological Emergencies” which states that “The quality of the required emergency preparedness is maintained by periodic training courses for on-site and off-site administrative personnel, including state government officials and various other stakeholders. Also, the primary evaluation of the same is based on periodic mock-drills and exercises. A large number of organisations/agencies like the police, fire and emergency services, medicos, paramedicos, non-governmental organisations, civil defence and home guards, etc., have to be fully integrated into the nuclear emergency programmes both at the state and district levels. State governments will undertake actions in a proactive manner to establish formal linkages of these organisations with the nearest Emergency Response Centre. ” None of these requirements have been complied with.