Questions, Questions, No Answers (Part II)

See: Questions, Questions, No Answers (Part I)

S. P. Udayakumar

Idinthakarai, Tirunelveli District, Tamil Nadu

November 22, 2011

[10] The “Presentation†claims that “[n]o radioactivity release through the sea water cooling is possible†not because there will be no radioactivity but because “this loop is physically separated by three levels from the coolant loop which enters the reactor.†The “Presentation†does acknowledge that “some low and medium level waste would be generated in the station which is treated inside the plant. Very low level effluents from these would be generated.†But there is hardly any more concrete information about this important issue and the report simply says “there are norms and limits for their releases.†Gaseous routine emissions will be there and they are “filtered in High Efficiency Particulate Air (HEPA) and Activated Charcoal filters before discharge to the Stack.â€

According to the report, the “authorized limit of low level effluents through air and water from KKNPP is restricted†and “it will not lead to more than around 4.36 percent of the dose limit for the public recommended by ICRP (1mSv). The limits of concentrations in aquatic and atmospheric releases are fixed in such a way that “the dose will never exceed the authorized limits†and the concentrations of discharges through stack are monitored continuously. The “Presentation†also says that the “activity levels of liquid discharge are monitored daily to ensure this.†Moreover, the environmental survey program of the ESL will assess the impact on the flora and fauna and in estimating the dose to members of the public. ESL is said to be monitoring the environment around the plant and has been collecting and analyzing samples of water, air, soil, flora and fauna from 2003, which forms the baseline data. The report says “[t]his activity will be continued throughout the entire lifetime of the Plant and records maintained.â€

The “Presentation†says: “we feel that the radiation safety of the people around KKNPP is guaranteed and there would be no impact of the operation of the power station on the public.†Although people in the high background radiation areas of Kerala are exposed to more than 10 times the natural radiation, “no deleterious effect could be noticed†among them. The report further claims “no genetic effects even amongst the progenies of the Hiroshima Nagasaki atomic bomb victims.†The report questions: “When this is the fact how a small percent (1%) of the natural radiation does that might be received around nuclear power stations lead to any genetic effect or cancer incidence?†The report concludes: “The fear about genetic effects of radiation around nuclear sites is more psychological and is contrary to scientific facts.â€

The report talks about collecting baseline data on health concerns. If the health concern is only “psychological†why should we “evaluate the impact due to the operation of the station later†? The report concludes that “investigations show that only certain type of cancers notably that of thyroid is due to the effect of radiation.†Dr. Shantha, a member of the Expert Group, has said that there is no connection between radiation and cancer (Dinamalar, November 19, 2011).

[11] The report lists the following population:

[12] The safe grade elevation of KKNPP site is 7.5 m above MSL and a shore protection bund is constructed along the shore to a height of 8 m to MSL. It is pertinent to note the tsunami waves of December 26, 2004 reached the top of Thiruvalluvar statue that is 133 feet high.

[13] According to the report, “the lethal temperature of fin & shell fishes was found to be between 38.2 and 43.2 C.†The maximum possible surface sea water temperature of Koodankulam areas is 29 C during summer months and the temperature rise is stipulated by MoEF as 7 C. The maximum temperature at discharge point will be 36 C which may not harm any fish. The report asserts that “fish, being a cold blooded animal, it can adjust the body temperature with that of environment within the sub lethal temperature and a rise in body temperature will enhance all biological activities, including growth and production.†The report also establishes that “the fish and prawns will have the capacity to sense the change in temperature in ambient water and try to avoid and move away from the adverse condition, if any, from the point of discharge.†Although the report claims that Tarapur and Kalpakkam plants have not “shown any adverse effects on Marine life including the fish.â€

[14] The “Presentation†claims that “there will not be any impact on the land environment as discharges are insignificant.†According to the EIA, the land use classification in 30 kms radius of the plant site based on satellite mapping. The land use/land cover classification indicates 8.73% area covered by vegetation, 8.73% are covered by barren land, 23.39% are covered by scrubland, 8.52% area covered by sandy area, 0.08% built-up area, 49.68% water body including sea, river etc.

[15] KKNPP is located in Indian Seismic Zone II, the least seismic potential region. The “Presentation†also claims that the most intense earthquake experienced in the 300km region is the one that occurred at Coimbatore on 08/02/1900 (6.0 in the Richter scale). There have been quite a few significant tremors in the Koodankulam area. On February 9, 2003 at 9:45 pm there was a tremor at Palayankottai. On March 19, 2006 at 6:50 pm there were tremors at several villages around Koodankulam such as Kannankulam, Anjugramam, Azhagappapuram, Mylaudi, Swamithoppu etc. On March 21, 2006 at 1:30 am and 5:00 am there were tremors in Karur district. In August 2011 there were tremors in 7 districts of Tamil Nadu. On November 19, 2011 at 4:10 pm, there was an earthquake south of Kanyakumari that measured 5.2 on the Richter scale.

[16] The “Presentation†claims that the “emergency exercise including the off-site emergency exercise that may require evacuation of a section of the population, are carried out accordingly.†In fact, no such exercise has been done so far. It is claimed that “emergency plan for actions to be taken in public domain during any off-site emergency were prepared and provided to District Authorities.†It is not clear when and what was done.

Emergency procedures are included in “Emergency Preparedness Plans†Vol-1 and Vol-2 documents. The KKNPP plants are tested periodically by conduct of emergence exercises such that any deficiency can be observed and corrected. Plant emergency exercise is conducted once in 3 months, site emergency is conducted once in a year, and the off-site emergency is conducted once in two years. A detailed training program was conducted by the District Collector for the officials from Revenue, Social Welfare, Fire, Health, Agriculture, Fisheries, Irrigation, Forest, Animal Husbandry, Electricity Board, Transport, Local Administration and police departments.

[17] The sanctioned cost of the KKNPP 1 & 2 is Rs. 13,171 crores including interest during construction. About half of the cost is financed by Russia and it has to be repaid in 14 annual installments after the commissioning of the plant. The report claims that the “set back in project completion schedule has resulted in revision of the cost estimates.â€

[18] The decommissioning cost is met by a levy of 2 paise per Kwh charged along with tariff to create a corpus. This levy is reviewed periodically to meet the fund requirements and revised. Some of the Indian NPPs have undergone significant renovation and modernization activities including replacement of components like pressure tubes and fittings, feeder pipes etc. This experience has demonstrated that “technology for such dismantlement activities, that are similar to decommissioning, is available in the country.†The radioactive waste arising from decommissioning is not significantly different from normal operation although its volume will be comparatively large. According to the report, “In India we have good experience in handling and disposal of such waste.â€

In the final analysis, this “Presentation†is hardly scientific and does not tell anything concrete or useful. This wishy-washy report does not allay the fears and concerns of the people; in fact, it aggravates the people’s fears by hiding all the vital information about the KKNPP project. The PMANE expert team that is going to meet on November 27, 2011 in Chennai will respond to this “Presentation†officially.