QUESTIONS TO THE EXPERT COMMITTEE ON KUDANKULAM NUCLEAR PLANT BY THE PEOPLE

Prof Shivaji RaoProf. T. Shivaji Rao, Director, Center for Environmental Studies, GITAM University, Visakhapatnam

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1 (a) According to US Nuclear Regulatory Commission the standards of safety for Nuclear Power Plants require preparation of Environmental Assessment Report including Risk Analysis, Nuclear accident scenario, Emergency preparedness plans and Disaster management reports for nuclear accidents caused due to several reasons including terrorist attacks and security threats.  See here

(b) Have similar reports been prepared for the Kudankulam Nuclear plant by the Nuclear Power Corporation of India and the Union Government. If, yes, place the reports before the people for obtaining their consent?

2 (a) Environmental Impact Analysis and Emergency preparedness plans have to be prepared and circulated for a public hearing as per Environmental Protection Act regulations and guidelines issued by the National Disaster Management organization under the Chairmanship of the Prime Minister of India?

(b) Did the Kudankulam nuclear plant authorities prepare such environmental Impact Assessment reports as per the rules of the Environmental Protection Act, 1986 and submitted the detailed reports, the damaging impacts of the proposed nuclear plant on the environment including the risk analysis ,nuclear plant accident scenario, Emergency preparedness plans and presentthem for a public hearing as per rules and taken the consent of the people likely to be effected by the emissions of pollutants from the plant during its routine operations and also due to a maximum credible accident caused by several reasons including internal sabotage, earthquakes, cyclones, terrorist attacks, aeroplane crashes or other hazards like Tsunamis and flooding?

3 (a) Is it not a fact that for the maximum credible anticipated nuclear accidents the US Regulatory commission prepares the emergency planning zones for 2 regions namely Plume Exposure Pathways (EPZ-I) zones covering a distance upto 16km downwind of the nuclear power plant. Predetermined protective action plans are in place for this EPZ and are designed to avoid or reduce dose from potential exposure of radioactive materials. These actions include sheltering, evacuation, and the use of potassium iodide where appropriate .

The second zone, known as the ingestion exposure pathway (EPZ-II) zone covering a distance upto 50miles or 80km from the Nuclear plant. Predetermined protective action plans are in place for this EPZ and are designed to avoid or reduce dose from potential ingestion of radioactive materials. These actions include a ban of contaminated food and water.  See here.

(b) Have such emergency planning zones prepared for nuclear accidents in USA are being implemented for the nuclear plant at Kudankulam? Such plans are essential for the public health and Environmental Protection standards in India and have to be more stringent for Indian people than even for the Americans who have with better nutritional and health standards.

(c) Have the lakhs of people of Tiruneveli city and district (in case of accident during southerly winds) /Trivandrum city and districts (in case of accident during southeasterly winds) been told that in case of an accident, they have to be evacuated and relocated in safer places for twenty years?

(d) Have lakhs of people downstream of the reactor in Tamil Nadu ( in case of accident during southerly winds) and Kerala (in case of accident during southeasterly winds) to be evacuated and relocated in safer places for 5 to 10 years for some villages and towns upto 110km from the plant and other villages and towns upto 170km for 1 to 4 years downstream of the plant.

4 (a) According to the National Disaster Management Report, Union Ministry of Home Affairs, (August, 2004) Development cannot be sustainable unless Disaster Management is built into the Development process. The approach for disaster management is translated into a natural disaster management road map covering institutional mechanisms including prevention, early warning, disaster mitigation, preparedness and emergency response through inputs from National, state and District levels as identified and listed in the road map contained in the official website. The procedures to be followed for disaster management as stipulated by the Government of India are naturally applicable for the development project pertaining to Kudankulam nuclear plant.

(b) In the case of handling the emergency due to a maximum credible accident at Kudankulam nuclear plant, what are the actions taken by the Union Government and the nuclear plant management authorities to enlist the active participation of the Tamil Nadu state Government, the regional District collectors and the local Panchayat officials including the police, defence and other concerned agencies in chalking out a road map of disaster management for the nuclear plant at Kudankulam? If the detailed reports on the involvement of the state and central Government organizations for this disaster management are prepared, these reports may be made available to the people for creating the required awareness of the problem among them and for enlisting their whole hearted cooperation in disaster management and for protecting their health and their lives and properties in the regions.

5 (a) The economic damaging costs of the 1100 MW nuclear plant accident postulated for the Sizewell reactor [about 150km , North East of London] were estimated in 1983 at £800 million. See here, here and here.

(b) Have such economic costs of damage been made for a maximum credible accident for the 1000 MW nuclear power plant proposed at Kudankulam for Tamil Nadu (in case the accident occurs during southerly winds) and Kerala state (in case the accident occurs during southeasterly winds)?

6 (a) The costs of decommissioning of a nuclear plant in USA have been estimated at $500 millions. See here.

(b) Has a similar estimated cost of decommissioning of the Kudankulam reactors at the end of their life have been made and presented to the people in India for their consent?

7 (a) The amount of compensation for victims of nuclear accidents to be paid in some countries is estimated to range from $300 million to $375 million by the nuclear plant operators while the total damaging costs is estimated at $ 12000 million under the Price Anderson Act of USA. In India it is estimated that the accident liability is proposed to be limited to a small amount of Rs.1500 crores by the nuclear plant operator/supplier in India while a major amount of compensation to the victims is proposed to be paid by the Union Government by diverting the poor tax payers money and thereby provide huge subsidies for the foreign contractors and the Indian operators to the detriment of public interest as already experienced in the case of Bhopal disaster.

(b) Did the Union Government take the consent of the people of India for making such efforts to over burden the poor tax payer to subsidize the enormous costs of the hazardous nuclear power? See here, here, here and here.

8 (a) MIT experts in their report on nuclear energy warned the industry that in order to ensure safety there must be continuous training of nuclear plant workers to continually observe and evaluate the emerging safety problems in the operation,and maintenance of the reactors. Since India is importing different kinds of modern reactors from different countries and India does not have the required scientific and technical man power to operate the reactors safely.

(b) Does the Government of India and the nuclear establishment authority realize that some of these advanced reactors are not fully tested even in their countries of origin and those countries also do not have properly trained and experienced persons there is very little chance either to import the man power from the concerned foreign countries or to send Indians for training to those countries for proper training. Under these circumstances how can the Indian Government and nuclear establishment import such modern reactors without proper working knowledge about them and at the same time assure the people of India that these reactors can be operated and maintained properly without compromising on safety standards. Since an automobile Engineering Professor may not be a good car driver and an experienced car driver may not be a good teacher of Automobile Engineer. It is very difficult to ensure harmonious operation and maintenance of a new machine by a new mechanic without proper reconciliation between the principles of the design of the plant and the mechanics of its operation. What can be done to ensure safety at Kudankulam reactors? See here.

9(a) In order to determine the frequency of nuclear accidents we depend upon either the historical experience or probabilistic risk assessment. In USA since 1957 Light Water Reactors are working with a total experience of 3700 reactor years till today and there was one reactor core damage accident at Three Mile Island and hence the core damage frequency of American reactors is one in 3700 reactor years on average[.for 104 Reactors] For probabilistic Risk Assessment (PRA) the method identifies possible failures in the reactor like pipe breaks or loss of reactor coolant flow and then traces the sequence of events that follow and finally estimates the likelihood of such failures resulting in core damage. PRA includes both internal events and external events like natural disaster, experts, estimate PRA for core damage frequency at 1 in 10000 reactor years for reactors in USA, with regard to global reactor growth in 50 years from 2005 to 2055 both historical and PRA data show unacceptable accident frequency estimated at 4 and one major accident may occur before 2055 as per estimates by experts.

(b) Under the above circumstances how can Indian Government take a calculated risk to opt for nuclear power plants knowing that they are risk prone and highly costly as compared with natural gas or thermal coal? See here, here and here.

10(a) In the case of the new reactors the designs use passive and active features to enhance reactor safety. Passive systems use stored energy for pumping either by means of pressurized tanks or by gravity acting on water in elevated times. See here.

They substitute for motor driven pumps ultimately driven by emergency diesel generators and can thereby remove the risk of failure of diesel generators to start when needed,, i.e. during a station blackout.

(b) But when these advanced reactors are subjected to internal sabotage, terrorist attacks or aeroplane crashes or bombing as had happened in Washington in September,2001, how can the Government and the nuclear plant authorities prevent a nuclear plant explosion even at this new generation of advanced nuclear reactors at Kudankulam.

11 (a) There is a public demand for the conversion of the Kudankulam Nuclear power plant into either a gas based, lignite or coal based thermal plant because the people believe that in order to protect the quality of the marine fishery resources which form their bread and butter that ensures their right to livelihood and right to life, this transformation of the nuclear plant into a thermal plant is in order. The people are confident to get the environmental damages minimized by employing state of art technology for the thermal power plants and hence their demand is justified. Moreover the latest expert committee report from the Massachusetts Institute of Technology, USA (2009) shows that nuclear power is not only highly hazardous but also more costly because it is estimated that one KWh costs about $0.08 for nuclear power and only $0.05 for either coal or natural gas based power.

(b) In the light of the public demand for more safer and economical sources of energy why should the Government of India or the state Government accept this just demand of the people to abandon riskiest nuclear power plant in preference to a gas based or coal based thermal plant by utilizing the infrastructure created for the nuclear plant at Kudankulam, as the best alternative that should have been suggested as per the guidelines specified in the proforma under the Environmental Impact Assessment report.

(page 33 Appendix-III alternatives to be suggested)

12(a) India is working with different kinds of nuclear power plants like Boiling Water Reactors based on American models at Tarapur supplied by United States, Pressurized Heavy Water Reactors (PHWR) at Kalpakkam and other stations based on Canadian models, VVER reactors at Kudankulam based upon Russian models. Consequently there are bound to be major variations in the procedures followed for construction, operation, maintenance, storage of wastes and decommissioning including safety and disaster management and waste disposal including reprocessing of wastes and recycling and reuse.

b) What are the various methods adopted by the Department of Atomic Energy for ensuring uniform standards of safety management, reactor monitoring, waste management, waste storage facilities, monitoring and management and emergency preparedness and implementation at these different plants?

13(a) It is reported that in some countries with imported reactors from foreign countries the fuel is often imported from the concerned foreign countries and the spent fuel is sent back again to the same countries for reprocessing, reuse and disposal.

(b) What methodologies are followed in India in case of the different reactors imported from different countries for the required fuel supplies and for reprocessing spent fuels from different reactors? Are there any problems like nuclear incidents and accidents during the handling, transportation and reprocessing of these nuclear materials that cause public health hazards?

14 (a) As per the newspaper report, the Hindu dt. 15, July, 2011 the disaster management even in the National capital of Delhi is in shambles and the terrorists attacks are repeated because of the mileage the terrorists are able derive since the Disaster management work is mired in red tape with bureaucratic ego multiplicity of authority and lackadaisical approach towards carrying out even basic task (for promoting environmental safety) and public safety, like mock-drills making a mockery of entire rules and regulations under the Disaster Management Act 2005.

(b) Under such poor work culture in the Indian Environment, what kind of guarantee can the expert committee members, nuclear plant authorities, Tamil Nadu State Government and the Union Government can provide for ensuring public safety and environmental safety and preventive management and control methods for the safety of the terrestrial and aquatic ecological systems in and around the nuclear plant for distances upto hundreds of kilometers in case of a nuclear accidents . See here.

15(a) For compensating the victims of Fukushima reactor accident, Japan Government and the nuclear plant operators are taking adequate legislation to pay very heavy amounts towards compensation ranging from an amount of Rs.3 lakh crores to Rs.5 lakh crores over a period of 2 to 3 years or more.

b) Has the Tamil Nadu state Government the Union Government and the nuclear plant authorities have taken steps to take insurance policies and pass laws to cover costs of compensation for the Kudankulam nuclear plant to an extent of Rs.5 lakh crores with the approval of the people of the state and the nation as per democratic norms governing a social welfare state? See here.

16(a) Union Government has got civil liabilities for nuclear damage Act passed in September 2011 and that compensation will be paid to the victims of nuclear accidents under different stages with the funds being paid by the industry (Rs.1500 crores /US$334.5million) the Union Government and also from International funding. The nuclear reactors may cause accidents either due to faults of the designs and equipments provided by the suppliers or due to mistakes or errors committed by the plant operators or by a combination of mistakes committed by both the suppliers and the operators.

b) (1) In the event of incidents and accidents in operating such nuclear power plants how are the costs of damages shared between the suppliers, the operators, the concerned state Government, the Union Government and the other International organizations like International Atomic energy Agency?

(2) To what extent such damage costs influence the increase in the cost of living of the common people of the concerned state and the country?

(3) How does the Nuclear Liability Act 2011 protect public interest if its implementation will let free the manufacturer, supplier and also the operator i.e. Nuclear Power Corporation of India(NPCIL) legally and to a large extent financially as well?

(4) If the Nuclear Liability Act does not allow the victims to sue the manufacturers and suppliers of nuclear plants which may cause any accident how does it protect the rights of the people of India guaranteed under the constitution?

(5) If under the nuclear liability Act 2011 according to clause 7 the operator pays compensation upto Rs.500 crores to the victims and the Union Government will pay additional amount. But the foreign companies liability is limited to Rs.1500 crores if there is a written contract. Is it justified in public interest?

(6) The Japanese Government proposes to pay Rs.3 lakh crores for victims of Fukushima accident and the Price Anderson Act in USA compensates victims for about 60,000 crores how can justice be done to Indians likely to be victims of a nuclear plant accident.

http://en.wikipedia.org/wiki/Nuclear_Liability_Bill

http://www.world-nuclear.org/info/inf67.html