E.A.S.Sarma
14-40-4/1 Gokhale Road
Maharanipeata
Visakhapatnam 530002

To

Dr.Manmohan Singh
Prime Minister

Dear Dr. Manmohan Singh,
Subject:- Safety of nuclear technology- Further studies in Germany confirm the accident risk

This is in continuation of my letters of December 11, 2011 and May 1,2012 on the high accident risks and the enormous cost of nuclear power. I enclose copies of both the letters for your ready reference.

Unfortunately, the Department of Atomic Energy (DAE) that you head is constantly in a denial mode on the genuine safety concerns that have arisen in the public mind after the Fukushima tragedy. Instead of learning from Fukushima events as they have unfolded day after day and updating its own safety calculations, DAE has launched a campaign to
“market” its technology.

Till date, despite a public assurance given by PMO in April last year, DAE has refused to place in the public domain the reports on the past safety audits on the existing nuclear power plants and the action taken on those audits. DAE should have disclosed this basic information under section 4 of the RTI Act by now. No wonder that DAE’s credibility has come under the scanner of public scrutiny. The more that DAE hides from the public, the more will be the damage to
its credibility. As the Minister in charge of DAE, you should introspect on this and take appropriate action.

I have come across a disturbing research study published on May 12, 2012 by Jos Lelieveld of Max Planck Institute for Chemistry at Mainz (Germany) with two other of his research associates in Journal of Atmospheric Chemistry & Physics (www.atmos-chem-phys.net/12/4245/2012). I have enclosed a copy of the paper for your information, in case PMO has not cared to keep tab on the emerging research literature on the subject of safety of nuclear power. I am not sure whether DAE has ever kept your office informed on the scientific research work that is in full swing all over the world on this vital subject of safety.

The study cited estimates the probability of a serious nuclear accident, the radioactive contamination it is likely to cause and how extensive it is likely to be.

You are aware that around 440 nuclear reactors are in operation today all over the world. The majority of them are of obsolete design and have outlived their age.The global experience of nuclear reactors is hardly 14,500 reactor years. There have been three major accidents already, one at Three Mile Island, another at Chernobyl and more recently at Fukushima, apart from thirty odd near-miss accidents. NPCIL’s repeated assertions that the fact that no major accident has taken place in any one of its reactors betrays its lack of appreciation of the science of statistical estimation.

Pressured by the nuclear manufacturing MNCs and their parent governments, countries like India and China have embarked on a massive expansion programme, without trying to scientifically assess the risks involved.

Based on the track record of the existing reactors in the world, Jos Lelieveld and his colleagues have estimated the probability of occurrence of a disastrous accident of the Fukushima kind and found that the risk is 200 times higher than the estimate for catastrophic, non-contained core meltdowns made by the U.S. Nuclear Regulatory Commission in 1990.

These researchers also calculated how the particles of radioactive caesium-137 (137Cs) disperse in the atmosphere, where they deposit on the earth’s surface and in what quantities. The 137Cs isotope is a product of the nuclear fission of uranium. It has a half-life of 30 years and was one of the key elements in the radioactive contamination following the disasters of Chernobyl and Fukushima.

The computer simulations revealed that, on average, only eight percent of the 137Cs particles are expected to deposit within an area of 50 kilometres around the nuclear accident site. Around 50 percent of the particles would be deposited outside a radius of 1,000 kilometres, and around 25 percent would spread even further than 2,000 kilometres.
These results underscore that reactor accidents are likely to cause radioactive contamination well beyond national borders!

From what one gleans from this thought provoking research study, it looks as though India has unwittingly joined the bandwagon of nuclear expansion that could expose vast stretches of its landmass and its dense population to an enormous radioactive exposure risk. While a major accident can have serious inter-generational health impacts over extensive stretches, one still does not know the health impact of low-intensity radiation to which the communities around the nuclear plants are constantly exposed. Apparently, we are dealing with the compound effect of a number of known and unknown risks that are inherent in nuclear technology. As the head of the political executive at the Centre and as the Minister in charge of Atomic Energy, I believe that you should pose the following questions to DAE.

1. Has DAE carried out detailed reliability engineering studies and probability assessments for its own plants, pre-Fukushima and post-Fukushima, in a manner that stands the test of scientific scrutiny? If so, the reports should be placed in the public domain under Section 4 of RTI Act. If not, DAE has a lot to answer the public and the Parliament on its failure to carry out such studies

2. Why has not DAE placed all the previous safety audit reports and the action-taken reports in the public domain despite PMO’s assurance in April, 2011? Has DAE something to hide?

3. Keeping in view the Fukushima experience, the zoning system adopted by US Nuclear Regulatory Commission (monitoring zone extends up to 80 km), why has not DAE reviewed the boundaries of the zoning system in our case? Why has not DAE taken the public into confidence, especially the people living in the vicinity of Kudankulam, Jaitapur and Kovvada, on the implications for them in each zone?

4. What is the response of DAE to the findings of the Max Planck Institute? Has DAE tried to get more details of the study and its implications for India?

Instead of resorting to public relations exercises, DAE should approach these issues more scientifically and put forward arguments that stand scientific scrutiny. Using celebrities to market nuclear technology can do more harm than good to DAE’s public credibility.

I strongly believe that the government has been pressurised by the nuclear manufacturing countries to go out of the way to launch a highly undesirable nuclear capacity expansion programme. Under the same pressure, it has enacted a civil nuclear liability law and rules that pass on huge invisible subsidies to the foreign reactor suppliers. The contingent liabilities on this account amount to Rs.20 lakh crores. Considering the cost differential between imported and indigenous reactors, the addition cost burden on the tax payer on account of heavy import dependence will be Rs 3,90,000 crores. If the additional cost of imported fuel were also to be taken into account, the cost burden would be much heavier. Simultaneously, as a result of such heavy dependence on imported reactors and imported fuel, India’s energy security is being compromised!

Considering the probability estimates that have since emerged from Max planck Institute, any responsible government worth its name would think twice before going ahead with such an ill-conceived nuclear capacity expansion programme.

Mr. Prime Minister, I appeal to you to think of all these disturbing features of nuclear technology and announce a moratorium on all nuclear power projects under construction and those proposed for the sake of national safety.

Regards,
Yours sincerely,

E.A.S.Sarma
Former Secretary to GOI
Visakhapatnam
23-5-2012