Eminent power policy analyst Mr. Shankar Sharma’s letter to the State Govt of Karnataka, after attending the public hearing on the Environmental Impact Assessment (EIA) for the expansion of Kaiga Atomic Power Station(KAPS)

To
The Chief Secretary
Govt. of Karnataka, Bengaluru

Copy:
(1) The Home Minister, Govt. of Karnataka, Bengaluru
(2) The Chief Minister, Govt. of Karnataka, Bengaluru

Dear Mr. Chief Secretary,

Greetings from Sagar, in Western Ghats of Karnataka.

A public hearing under the EIA Rule 2006 of MoEF&CC was held under the Chairmanship of DC, Uttara Kannada district on 15.12.2018 at Mallapur-Virje, Karvar Taluk, Uttara Kannada district over the Environmental Impact Assessment (EIA) report of the proposal on Kaiga NPP extension (Units 5&6) .

A serious issue noticed during this public hearing was the doubt over adequate preparedness on part of the concerned authorities during a scenario of uncontrolled radiation emission beyond the exclusion zone as can be expected in a large size nuclear reactor as in Kaiga NPP, and similar to what happened in Chernobyl (USSR) and Fukushima (Japan). During my oral submission I raised this issue with the Deputy Commissioner, who was also at the Chair during that meeting. No response was given by the DC for this specific issue, even though he chose to respond to many other issues raised by the participants in the meeting. It is not clear to me whether DC has realised the critical nature of this particular issue of adequate preparedness.

The EIA, which was provided by the project proponent in this regard, is without the necessary details, and seems to be keen to pass on all the associated responsibilities to the district administration, which is not acceptable to the people of the state. The following is the corresponding text in EIA.
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EIA Section 07.06.04: Off-site emergency
“An off-site emergency occurs when the radiological consequences of an emergency situation originating from Nuclear Power plant (NPP) are likely to extend beyond the site boundary (exclusion zone) and into the public domain. For the purpose of planning off-site emergency, an emergency-planning zone up to 16 km radius is specified. There are defined criteria to determine an off-site emergency in terms of the release of radioactivity as indicated by the radiation monitoring system/radiation survey results.
The protective measures in public domain shall be implemented by the district officials under the supervision of the district collector or the divisional commissioner, who shall be designated as the Off-site Emergency Director (OED).”

Action plan for declaration and termination of off-site emergency
“If there is an escalation in the site emergency situation warranting an off-site radiation emergency, the SED advises the OED to declare off-site emergency. District commissioner, Uttara Kannada takes over the charge of OED and initiates appropriate actions. Off-site emergency is declared by the OED on the advice of SED. Off-site emergency is terminated by off-site emergency director on the advice of off-site emergency response co-ordination committee.”
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As you may know, NPCIL is seeking ‘environmental clearance’ for adding two more nuclear reactors of 700 MWe capacity each to the existing capacity of 4*220 MWe capacity each at the existing project site of Kaiga village. With an increase of about 250% in the overall reactor capacity at the project site, the Kaiga site in Karwar taluk will face exponential increase in radiation emission risks with the presence of six nuclear reactors in close proximity with each other and sharing many technical services. Nuclear safety experts identify such a scenario as “enhanced risk for NPPs with multiple reactors and shared technical facilities”.

It is a general public opinion that the concerned authorities in the country are ill-equipped and ill-prepared to face such industrial level disasters as experienced in the case of Bhopal gas tragedy in 1984. Our authorities seem to become complacent over a period of time with the view that such a disaster may not happen in our country. Whereas, the nuclear power authorities may continue to claim the low probability of an uncontrolled nuclear radiation emergency in India, such statements from our authorities do not enjoy the trust of the people because of the plethora of reports from around the world on the unmitigated nuclear disasters experienced at Chernobyl and Fukushima. The EIA, itself admits that such an emergency cannot be completely ruled out. Even though the probability of an uncontrolled nuclear radiation emergency in Kaiga NPP may be low, as per the claims of EIA, the total consequences of a nuclear disaster to the district and the state as a whole can be horrendous. Hence, we cannot afford not to take all possible precautions.

Whereas, the project proponent, through EIA, seem to have shifted the actual responsibility of off-site emergency measures to DC by the statements as mentioned above, it should be noted that as the district administrator and also as the district magistrate, the DC has enormous and varieties of responsibilities even during normal times. It appears to be improper to expect such a busy official to appropriately react to such emergencies, unless he is ably assisted by a group of competent people, who are well trained and well equipped? EIA has no adequate explanations in this regard.

In this overall context, 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 number of all-weather roads 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 etc. trained and provided with necessary equipment to detect any radiation leakage and to take the necessary safety measures immediately? Have sufficient number of vehicles 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?

You may know that the district of Uttara Kannada is largely a hilly area, and the Kaiga NPP is in a valley surrounded by thick forests. The local communities, who are also the project-affected people, are spread over an area of about 800 sq. kM, as identified by the EIA. Since the habitats of these communities are in vastly undulating hills and river valleys, artificial reservoirs etc., and do not have well connected all-weather roads, quick evacuation in an emergency scenario will be a nightmare. As stated by the MLA of Karwar constituency in the public hearing, one of the urgent requirements of the local communities is a good number of well connected all-weather roads. The state govt. may like to ask the project authorities to share the costs and responsibility of building such a road network on a priority basis.

Since adequate remedial actions are critical during the first few hours of the identified emergency to minimise the loss of life, and since NDRF and SDRF teams are unlikely to be at the site during this period, there is a critical need for the state govt. to diligently consider all the associated issues, discuss with the NPCIL/DAE/AEC/NDRF officials, and ensure all the necessary measures are in readiness.

The horrors of Chernobyl and Fukushima disasters must have been the suitable wake-up calls for our authorities to honestly try and reduce the chances of such catastrophes in India, but sadly they are continuing to add more nuclear reactors at an ever increasing pace, thereby escalating the risks associated with nuclear disasters. Since, it will be the people of the Uttara Kannada district and of the state who will bear the brunt of such a nuclear disaster at Kaiga NPP, which has been thrust on us basically because of the policy blunder of a previous govt. to allow such a risky project in a such a hilly area covered with thick forests, it is of paramount importance for the present govt. to take all possible measures to minimise such risks and impacts.

In this context, I strongly urge the state govt. to advise the MoEF&CC urgently not to accord the environmental clearance for the proposed project until all the associated disaster management plans are thoroughly discussed and agreed to.

I also urge the state govt. to arrange to get the EIA report analysed by a group of experts in detail so as to clearly identify various risks, costs and impacts associated with the proposed project for the people of the state, and to consider the same from the proper perspective of the overall welfare of the state. I am enclosing the detailed submission sent to the DC, Uttara Kannada, district on the basis of a study of this EIA for your information. Whereas this 22 page submission has discussed many issues of concern to our people, I would like to highlight two specific issues here in addition to the issue of nuclear radiation risk, as described above.

1. The diversion of more than 54 Hectares of thick forest lands in this district for the proposed project (in addition to the forest lands needed for additional transmission lines) will negate the very objective of MoEF&CC and the state’s own ecological considerations, in the context that the proposed project area is in the reserved forest category, and also within the buffer zone of the Kali Tiger reserve. Additionally, the MoEF&CC has declared through the a Gazette notification on 3rd Oct. 2018 that the three villages of Kaiga, Mallapur and Virje identified for the project work in this EIA, as ecologically sensitive areas and should be conserved. The forest cover in the state is already known to be less than 20% as against the national forest policy target of 33% and 66% in the hilly districts such as Uttara Kannad.

Hence, the state govt. should not agree for the diversion of more than 54 hectares very think forest lands to the proposed project, even though the project proponent claims that that much of forest area is already under their possession, because of the blunder by a a previous govt..

2. Three reports from the scientists of IISc, Bengaluru under the title, (i) “Ecological Sustainability of Riverine Ecosystems in Central Western Ghats”, 2018; (ii) “Stimulus of developmental projects to landscape dynamics in Uttara Kannada, Central Westen Ghats”, ELSEVIER, 2016, and (iii) “Salient Ecological Sensitive regions of Central Western Ghats, India”, Springer Nature 2018, have all copiously highlighted the ecological importance of the area around Kaiga NPP. This emphasizes the need for the review of existing forest policies to ensure sustenance of ecological services through the sustainable forest management strategies. EIA also states that there will be additional fresh water demand of 9,000 cubic meters per hour (out of which about 6,346 cubic meter per hour will be for consumptive use) for the proposed project. This enormous quantity of fresh water (6,346 cubic meter per hour) for consumptive use as per EIA , to be drawn from the river Kali, will have considerable impact on the local environment and for the locals. The state of Karnataka, which has faced drought scenario in about 50% of its revenue sub-divisions in most of the years since year 2000, cannot afford to divert such a large volume of fresh water in the context of the projected drop in river water flow due to Climate Change. At the rate of 6,346 cubic meter per hour the water consumption in a day will be 152,304 cubic meters, which is 152,304 kilo litre of fresh water. At about 100 litre per day this can meet the daily water requirement of about 15 lakh people. Even though the project proponent claims that the bad policy of an earlier govt. of Karnataka had already allocated this much additional quantity of water from Kadra reservoir, the growing water demand for domestic and agriculture in the state should make the state govt. to seriously review this earlier allocation.

3. Keeping all these factors in proper perspective, it is evident that the area in and around the proposed project area is ecologically of very high value to the nature, and sensitive too, not just for the forest dependent locals, but also for the global concerns on Climate Change. MoEF&CC has been very emphatic that such areas must be protected, and hence must be insulated from all kinds of developmental projects. The state, the country, and the planet as a whole, cannot afford to lose more than 54 Hectares of tropical rain forest of very high ecological value to the nation’s and planet’s environment for the sake of an inconsequential additional power, as in the case of this project proposal.

4. Any commitment of the state govt. to allocate the additional quantity of 152,304 cubic meters of water per day to this project should also be seriously viewed in the context of potentially reduced availability of water in Kali river due to the impacts of Climate Change. Once committed, the nuclear power plant will continue to demand this much of water per day even during water availability crisis in the river, leading to a scenario where that much of water has to be given to the project even at the cost of the basic/domestic needs of the local communities.

5. Objectively considering various constraints of the prevailing state and the regional electricity grids, the proposed capacity of 1,400 MWe from this project will basically mean that on an average only about 800 MW of power will be available for the end use consumption, and that Karnataka’s share can only be about 400 MW of additional power. The question that should be carefully discussed is whether the state should lose more than 54 hectares of thick forests and about 152,304 cubic meters of fresh water per day from Kali river for a meager benefit of 400 MW, for which there are many benign alternative options available for the state at much lower overall costs to the state.

These and many other concerns are discussed in the written submission as in the enclosed file.

Considering all these issues in the overall welfare perspective of the people of Uttara Kannada district, region and the country, and in the context that nuclear power is the costliest, riskiest and least favored electricity option around the world, and that there are much benign and much less costly options to meet the legitimate demand for electricity in our country, the state govt. should take a clear stand with the MoEF&CC that Environmental Clearance to this project proposal should be summarily rejected.

If deemed necessary, I can provide additional clarifications.

Please arrange to acknowledge the receipt of this communication.

Regards

Shankar Sharma
Power Policy Analyst
Sagara, Karnataka