EAS Sarma, former Union Power Secretary, replies to the rejoinder by Dr KS Parthasarathy, former secretary, Atomic Energy Regulatory Board (AERB), to his letter addressed to the secretary, Department of Atomic Energy (DAE), Government of India, where he had talked of "worldwide anxiety about the consequences of catastrophic nuclear accidents, either due to manual lapses or natural calamities":
Dear Dr Parthasarthy,
I am delighted to have come across an excellent article of yours in Counterview, “Rejoinder: Worldwide anxiety post-Fukishima is fading, slowly and steadily”.
Rarely do I find responsible officials and those concerned with nuclear power development responding to letters from ordinary persons like me, who form part of the civil society.
By the by, you too, having retired from DAE/ AERB, have since become a valuable part of the civil society! The fact that you have read my letter on Kaiga and rebutted it point-wise gives me hope that there will be an informed debate in the coming years on nuclear power in our country.
In this connection, I wish to quote what the famous French writer, Voltaire said long ago, “I dispprove what you say, but I will defend to the death your right to say it". After all, science, especially, physics, would not have progressed but for the process of dissent and debate that it is still going through.
Specifically in the case of nuclear power, we should take note of the fact that the data on the number of reactor-hours till date is far too small for anyone familiar with stochastic estimation methodology to be able to say with a reasonable degree of confidence that the probability of a major accident at a nuclear power plant is far too negligible to be ignored altogether.
Even if it is negligible, the consequences of an accident being significantly large, the compound probability of the consequence of the occurrence of a calamity should still cause distress to anyone conscious of the value of human life.
Similarly, the effects of even low-dose radioactivity can be of concern. The so-called "threshold" safety levels will critically depend on how one values human health and life. The threshold will be high, if human life is valued low and vice versa.
I still remember how a suspected spill from a needle-point deposit of a radioactive isotope on which we were working in the Nuclear Spectroscopy division of TIFR in the sixties caused a great deal of fear and our colleagues in the TIFR "Hot Lab" came with Geiger Counters to assess the magnitude of the exposure. One of my fellow scientists had to be quarantined and cleansed for a couple of days to minimise the adverse impact! What applied then to the scientists should equally apply today to the people around Kaiga.
Nuclear risk assessments underwent paradigm changes when major accidents took place from time to time.
For example, when US NRC commissioned a risk assessment study on reactor safety under the chairmanship of Neil Rasmussen in 1975, those in the nuclear establishment criticised the report on the ground that it overestimated the risk probability. Their criticism paled into oblivion when Three Mile Island accident in 1979 shook the confidence of the establishment. Chernobyl in 1986 and Fukushima in 2011 have overshadowed the reliability studies of the past.
Since you have cited Para 184 ( Civil Appeal No 4440/2013), let me cite Para 89 of Madras High Court's judgement of August 2012 in W.P.No.24770 of 2011, which reads as follows:
“Even though it is stated that the said exercise [mock drill referred in the judgement] was done in only one village, namely Nakkaneri village, which is stated to be nearer to the KKNPP, as we are informed that nearly 30 to 40 villages are within 30 Kms radius of KKNPP, such event must take place in all villages and more importantly, apart from the officials, as stated above, the people in the area must be made to participate and an awareness programme must be made to infuse confidence in the minds of the local people that the project is for the benefit of the country and there is no need to alarm”.
Till date, DAE has not cared to comply with this direction nor AERB has cared to secure compliance of it! Why is DAE shy of holding such mock drills, which are routinely conducted in USA and Canada? US NRC insists on periodically conducting such mock drills, as they test the coordinated disaster preparedness of the Central and State agencies.
They put to test the availability of adequate quantities of iodine pills at convenient locations to the logistics of evacuation of the affected people to safe locations. Apparently, both DAE and AERB are living in a make-shift world of imagined safety. If an accident were to occur, their lack of preparedness would surely get exposed.
Let me invite your attention to a well established principle of jurisprudence known as the Precautionary Principle, which, in matters pertaining to the environment and human health, places the burden of proof of safety of an industrial technology on the proponents of that industry. When I addressed my concerns on Kaiga to DAE and AERB, the onus rests on those agencies to come forward and place their case before the people in proof of near 100% safety.
I am somewhat surprised at your argument that AERB is an "independent" regulatory authority. I do not have to remind you of the cliche, "Caesar's wife must be above suspicion". What matters is the public perception of a regulator's independence. As long as AERB remains sub-ordinate to DAE, it cannot be deemed to be "independent", however competent and objective its personnel may be.
Why is DAE dragging its feet on going ahead with processing the Nuclear Safety Regulatory Authority (NSRA) Bill? The very fact that there is hesitation on the part of DAE raises a serious concern about ARRB's autonomy. In my view, not enacting that law amounts to utmost negligence on the part of the government.
Coming specifically to the EIA study on Kaiga expansion project, don't you agree with me when I say that the study has failed to capture the essential concerns that ought to have been addressed by any consultants worth the remuneration they are paid?
A public consultation process cannot be treated as a ritualistic exercise to get clearances. The people of this country are the primary stakeholders in such large projects and their concerns are far too important to be ignored.
Technologies must subserve the public interest, not the other way. It will be a mistake for anybody to trivialise the public concerns.
May I once again thank you for taking time to rebut what I have said in the case of Kaiga expansion, because it has also prompted me to bring my own concerns in greater detail as expressed above?
I am marking copies of this letter to the Prime Minister (he is in charge of DAE), Chairman, AEC, AERB and others for information and for generating a rational discussion on the subject.
In this connection, I wish to quote what the famous French writer, Voltaire said long ago, “I dispprove what you say, but I will defend to the death your right to say it". After all, science, especially, physics, would not have progressed but for the process of dissent and debate that it is still going through.
Specifically in the case of nuclear power, we should take note of the fact that the data on the number of reactor-hours till date is far too small for anyone familiar with stochastic estimation methodology to be able to say with a reasonable degree of confidence that the probability of a major accident at a nuclear power plant is far too negligible to be ignored altogether.
Even if it is negligible, the consequences of an accident being significantly large, the compound probability of the consequence of the occurrence of a calamity should still cause distress to anyone conscious of the value of human life.
Similarly, the effects of even low-dose radioactivity can be of concern. The so-called "threshold" safety levels will critically depend on how one values human health and life. The threshold will be high, if human life is valued low and vice versa.
I still remember how a suspected spill from a needle-point deposit of a radioactive isotope on which we were working in the Nuclear Spectroscopy division of TIFR in the sixties caused a great deal of fear and our colleagues in the TIFR "Hot Lab" came with Geiger Counters to assess the magnitude of the exposure. One of my fellow scientists had to be quarantined and cleansed for a couple of days to minimise the adverse impact! What applied then to the scientists should equally apply today to the people around Kaiga.
Nuclear risk assessments underwent paradigm changes when major accidents took place from time to time.
For example, when US NRC commissioned a risk assessment study on reactor safety under the chairmanship of Neil Rasmussen in 1975, those in the nuclear establishment criticised the report on the ground that it overestimated the risk probability. Their criticism paled into oblivion when Three Mile Island accident in 1979 shook the confidence of the establishment. Chernobyl in 1986 and Fukushima in 2011 have overshadowed the reliability studies of the past.
Since you have cited Para 184 ( Civil Appeal No 4440/2013), let me cite Para 89 of Madras High Court's judgement of August 2012 in W.P.No.24770 of 2011, which reads as follows:
“Even though it is stated that the said exercise [mock drill referred in the judgement] was done in only one village, namely Nakkaneri village, which is stated to be nearer to the KKNPP, as we are informed that nearly 30 to 40 villages are within 30 Kms radius of KKNPP, such event must take place in all villages and more importantly, apart from the officials, as stated above, the people in the area must be made to participate and an awareness programme must be made to infuse confidence in the minds of the local people that the project is for the benefit of the country and there is no need to alarm”.
Till date, DAE has not cared to comply with this direction nor AERB has cared to secure compliance of it! Why is DAE shy of holding such mock drills, which are routinely conducted in USA and Canada? US NRC insists on periodically conducting such mock drills, as they test the coordinated disaster preparedness of the Central and State agencies.
They put to test the availability of adequate quantities of iodine pills at convenient locations to the logistics of evacuation of the affected people to safe locations. Apparently, both DAE and AERB are living in a make-shift world of imagined safety. If an accident were to occur, their lack of preparedness would surely get exposed.
Let me invite your attention to a well established principle of jurisprudence known as the Precautionary Principle, which, in matters pertaining to the environment and human health, places the burden of proof of safety of an industrial technology on the proponents of that industry. When I addressed my concerns on Kaiga to DAE and AERB, the onus rests on those agencies to come forward and place their case before the people in proof of near 100% safety.
I am somewhat surprised at your argument that AERB is an "independent" regulatory authority. I do not have to remind you of the cliche, "Caesar's wife must be above suspicion". What matters is the public perception of a regulator's independence. As long as AERB remains sub-ordinate to DAE, it cannot be deemed to be "independent", however competent and objective its personnel may be.
Why is DAE dragging its feet on going ahead with processing the Nuclear Safety Regulatory Authority (NSRA) Bill? The very fact that there is hesitation on the part of DAE raises a serious concern about ARRB's autonomy. In my view, not enacting that law amounts to utmost negligence on the part of the government.
Coming specifically to the EIA study on Kaiga expansion project, don't you agree with me when I say that the study has failed to capture the essential concerns that ought to have been addressed by any consultants worth the remuneration they are paid?
A public consultation process cannot be treated as a ritualistic exercise to get clearances. The people of this country are the primary stakeholders in such large projects and their concerns are far too important to be ignored.
Technologies must subserve the public interest, not the other way. It will be a mistake for anybody to trivialise the public concerns.
May I once again thank you for taking time to rebut what I have said in the case of Kaiga expansion, because it has also prompted me to bring my own concerns in greater detail as expressed above?
I am marking copies of this letter to the Prime Minister (he is in charge of DAE), Chairman, AEC, AERB and others for information and for generating a rational discussion on the subject.
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