March 24, 2012

The People’s Movement Against Nuclear Energy (PMANE)
Idinthakarai & P.O – 627 104
Tirunelveli District
[email protected]

The Chairman
Atomic Energy Regulatory Board
Niyamak Bhavan
Mumbai 400 094

Dear Sir/Madam:

Greetings! We, the people of southern districts of Tamil Nadu and Kerala have been struggling against the Koodankulam Nuclear Power Project (KKNPP) at Koodankulam in Tirunelveli district, Tamil Nadu, India since its inception in the 1980s.

The KKNPP reactors from Russia are being set up without sharing the Environmental Impact Assessment (EIA), Site Evaluation Study and Safety Analysis Report with the people, or the people’s representatives and the press. No public hearing has been conducted for the first two reactors either. The KKNPP project has been imposed on an uninformed and unwilling population throwing all democratic precepts and values of our country to the wind.

The people of Tamil Nadu and Kerala are deeply concerned about our safety and wellbeing as the KKNPP reactors pose grave and serious threats. The actual siting of the reactors, the quality of construction and the pipe work and the overall integrity of the KKNPP structures have been called into question by the very workers and contractors who work there in Koodankulam. Similarly, the then Minister of State in the Ministry of Environment and Forest (MoEF) Mr. Jairam Ramesh announced a few months ago that the central government had decided not to give permission to KKNPP 3-6 as they had violated the Coastal Regulation Zone stipulations. It is pertinent to point out that KKNPP 1 and 2 are also violating CRZ terms.

The 2004 December tsunami did flood the KKNPP installations. There was a mild tremor in the surrounding villages of Koodankulam on March 19, 2006. On August 12, 2011, there were tremors in 7 districts of Tamil Nadu. These happenings heighten our anxieties and worries about the possibility of natural disasters occurring in the project area.

Similarly, more than 1.5 million people live within the 30 km radius of the KKNPP which far exceeds the AERB stipulations. It is quite impossible to evacuate this many people quickly and efficiently in case of a nuclear disaster.

There have been international concerns about the design, structure and workings of the untested Russian-made VVER 1000 reactors. Even a Russian government-sponsored study has found serious issues with the VVER 1000 reactors.

The issue of liability for the Russian plants has also not been settled yet. Defying the Indian nuclear liability law, Russia insists that the Inter-Governmental Agreement (IGA), secretly signed in 2008 by the Indian and Russian governments, precedes the liability law and that Article 13 of the IGA clearly establishes that NPCIL is solely responsible for all claims of damage.

Our expert team has identified several serious safety issues with regards to the KKNPP project which we have listed below.

Most importantly, the KKNPP and the Nuclear Power Corporation of India Ltd. (NPCIL) officials have not conducted any mock drills and evacuation drills in the 30 km radius. The NPCIL informed us in its letter dated January 9, 2012 (No. NPCIL/VSB/CPIO/1400/KKNPP/2012/44) that Off-site “Emergency Exercise has not been carried out in KKNPP.” In a subsequent letter dated February 16, 2012 (No. NPCIL/VSB/CPIO/1598/KK/2012/300) NPCIL stated: “As per the AERB guidelines, offsite emergency exercise shall be conducted prior to regular operation of a Nuclear Power Plant. AERB guidelines will be followed in KKNPP in this regard.” However, we hear reliably that the KKNPP officials are trying to load the fuel rods in the reactors against the AERB and other international stipulations.

In the light of the above situation, we would very much like to request you to intervene in the KKNPP matter and stall its commissioning. Looking forward to hearing from you soon, we send you our best regards and all peaceful wishes.


S.P.Udayakuamr, Ph.D.
Coordinator: PMANE

[1] Issues PMANE Expert Team Has Identified

Copy to:

International Atomic Energy Agency
Vienna International Centre
P.O. Box 100
A-1400 Vienna

United Nations Environment Programme
United Nations Avenue, Gigiri
PO Box 30552, 00100
Nairobi, Kenya

International Committee of the Red Cross
19 Avenue de la paix
CH 1202

The Head
Safety Research Institute
IGCAR Campus
Kalpakkam 603 102
Tamil Nadu

Amnesty International
1 Easton Street
Lonndon WC1X 0DW

International Alert
346 Clapham Road
London SW9 9AP

Human Rights Watch
350 Fifth Avenue
34th Floor
New York, NY 10118-3299

Issues PMANE Expert Team Has Identified

1. The Koodankulam site is not only prone to small-volume volcanic eruptions, but also to mega-tsunamis with heights exceeding 100 feet, arising out of the presence of two large “slumps” in the seabed of Gulf of Mannar less than 100 km from the plant. A 1982 study in a noted journal documents the presence of two slumps — the East Comorin slump and the Colombo slump — in the vicinity of the Koodankulam site. The second report by the Central Govt Expert Group has accepted the presence of the slumps and the possibility of a Near Field Tsunami occurring out of a landslide. This is in opposition to their earlier position and also to the position of AERB that Near field Tsunamis are not possible in India. However, their contention is on the height of the Tsunami waves. While welcoming their change in accepting the possibility of Near Field Tsunami, the PMANE Expert Team wishes to state that after the 1982 study, a tsunami did occur in December 2006 and it may have changed the structures of the Slumps. Hence merely answering the question from the 1982 text is not sufficient.

2. PMANE’s Expert Team is alarmed that NPCIL has allowed the siting of the plant in an area characterised by sub-volcanic intrusions – an indication of volcanism in the vicinity of the plant. The presence of sub-volcanic intrusions of the kind found in the KKNPP site is precisely the reason why the United States Government abandoned the Yucca Mountain site as a possible waste storage site owing to concerns about the structural integrity. In addition to this, small volume volcanic eruptions have occurred in the KKNPP site’s vicinity from the year 1998.

3. Studies by Oil and Natural Gas Commission (ONGC), the Geological Survey of India (GSI) and numerous other terrestrial and marine geologists confirm the presence of basaltic intrusions into the crust and the Gulf of Mannar seabed. Their findings tell us that the Gulf of Mannar sea bed has been thinned because of this. Its thickness is a mere 1,000 to 5,000 metres instead of average 40,000 metres for continental crust.

4. Scientists from various national institutes have published as late as 2010 that the crustal thickness of Koodankulam site is much thinner than the Gulf of Mannar Crust because of similar sub-volcanic intrusions. Ground Magnetic Surveys conducted by them have suggested that the Crustal thickness is a mere 150 to 200 metres at Koodankulam site.

5. The entire Koodankulam region is known for its lime stone formations. Lime stone formations are known to the formation of Sink holes and underground caves. Events that occurred on November 26, 2011 at Pannaiyarkulam, in 2008 at Radhapuram (both located 10 kms from the KKNPP site), and in 1998 at Maruthankulam (25kms from the KKNPP site) have suggested that this is a “KARST” Region. AERB’s safety laws clearly state that if a Karst region is suspected a detailed study has to be conducted. Such a study has not been attempted by the NPCIL.

6. During the 2004 tsunami the withdrawal of the sea was around 4-5 Kms from the shore. Every year after this tsunami, the some places of the coast of Tamil Nadu have faced the issue of sea water withdrawal at least 3 times a year. Tsunami hazard manual released by the USNRC in March 2009 states that if sea water withdrawal is an issue at the site then the chances of the reactor going in for a dry intake should be studied thoroughly. Dry intake can cause damage to the turbines and reactors. Each minute a reactor needs 5,000 cubic-metres of sea water. Hence a detailed volcanic hazard study, tsunami hazard study and a study about the “Karst” Terrain is a must.

7. Another crucial failure of the NPCIL is the fact that the plant has been assured supply of freshwater for merely 36 hours and 25 minutes. The dependence on a single source, namely, the desalination plants, further reduces the reliability of this water source because desalination plants rely on the sea and electricity. Both can be disrupted by disturbances in electricity supply and cyclones and extreme weather events in the sea along with Jelly fish intrusions. In such a situation, reactors will have to be closed down immediately and they may have just enough water for maintaining the safety systems for only 10 days. The reserve of potable water for the KKNPP Township is sufficient only for 2 days. The seawater intake pipeline of the Minjur desalination plant in Thiruvallur district was uprooted during the Cyclone Nisha in 2008. Repairing the pipeline required engineers from the Netherlands and it took more than 45 days to mend the pipeline.

8. Department of Atomic energy (DAE) funded study by Dr. Manjula Datta has found that the morbidity burden in the proximity villages of Kalpakkam is 400% higher than in distant villages. The diseases include Cancer, mental retardation, thyroid problems, infertility, lumps, stroke, cataract, TB, ulcer and diabetes. Another study conducted by Dr. V. Pugazhendhi et. al. showed that auto immune thyroid disease among women living in upto 40 kms from the Kalpakkam site was significantly higher than those living 500 kms away. In another study conducted by the same doctor in 2003 among the Kalpakkam employees and family members had shown that the death rate due to Multiple Myloma (a bone marrow cancer) is statistically significant. Studies based on data supplied by the NPCIL shows that the prevalence of cancer among workers and wives of the BARC and the TAPS is significantly higher than that found in MAPS. The first 2 reactors became critical during the 1960’s and the 1970’s whereas the MAPS came critical during 1984-85. Yet another study shows significant deviation in sex-ratio of children born to employees of the BARC and the TAPS which is indicative of genetic mutations.