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Karnataka's Kaiga N-power expansion without 'adequate' risk, cost-benefits analysis

Counterview Desk 

In a representation to the the chairman and members of the National Disaster Management Authority (NDMA), well-known power and climate policy analyst Shankar Sharma has said that the recent approval for the addition of 2*700 MWe nuclear power reactors at Kaiga atomic power plant (APP) in Karnataka has led “to a lot of concern” to those who have a “modest understanding of nuclear power reactor accidents” in Chernobyl and Fukushima.
Sharma said, there are a number of “unanswered questions” with regard to the Kaiga APP among the local people, too, especially over “adequate preparedness on part of the concerned local authorities during a credible scenario of uncontrolled radiation emission beyond the exclusion zone.”


This has reference to a news item that "Senior officers of the National Disaster Management Authority (NDMA) concluded the two-day inspection at Kaiga Atomic Power Station in Karwar" in the Uttara Kannada district of Karnataka state in Sept. 2022.
I am a resident of Shimoga district, which is adjacent to Uttara Kannada district with its HQ at Karwar. I live in a town about 100 km away (aerial distance) from Kaiga APP site, and am naturally concerned about the totally unacceptable impacts of any unfortunate nuclear accident at Kaiga APP. I am an electrical engineer and a power sector professional with over 4 decades of experience in the power sector of India, New Zealand and Australia. I have a modest knowledge of nuclear power technology, and of the credible risks associated with that technology.
With this geographic and professional background, I want to share my views about the Kaiga APP and its general environment with NDMA, so as to assist it with some useful information in discharging its responsibilities.
I would like to start with the NDMA vision, which states: "To build a safer and disaster resilient India by a holistic, proactive, technology driven and sustainable development strategy that involves all stakeholders and fosters a culture of prevention, preparedness and mitigation."
Specifically, the words "pro-active" and "prevention" in this vision are of great appeal to me.
The recent approval for the addition of 2*700 MWe nuclear power reactors at Kaiga APP has led to a lot of concern to the local population, and to those in the state who have a modest understanding of nuclear power reactor accidents, as reported from Chernobyl and Fukushima. 
 My representation dated 23rd December 2018 to Atomic Energy Commission, should emphasise multiple concerns to our people on safety issues, which can be associated with the uncontrolled radiation leakage, along with many other issues of importance to the entire country.
Having gone through that EIA report (Environmental Impact Assessment report) of the proposal on Kaiga APP extension (Units 5 & 6), and having made both the written as well as oral submission at the associated public hearing, I notice that there are many serious concerns to the local stakeholders, as well as for the state and the country as a whole from the proposed project.
My principal concern has been that, whereas 4 nuclear reactors at Kaiga APP have been operating since the last few years, the addition of about 1.6 times the earlier capacity (an increase from about 840 MWe to 2,240 MWe capacity) in the proposed expansion plan will basically mean an exponential increase in "risk" associated with a nuclear reactor accident, the quantum of nuclear radiation leakage even in a normal operating condition, and the quantum of nuclear waste, including the spent nuclear fuels, which will be stored on the site.
Whereas, there have been a number of concerns with the statements made in the EIA report, as prepared for the Project proponent (NPCIL in the present case), the same is found to be seriously deficient in not considering: 
(i) adequate details of disaster management plan to safely evacuate more than 32,000 people of the region and rehabilitate them satisfactorily in the case of any unfortunate nuclear accident of the type noticed at Chernobyl and Fukushima; 
(ii) policy and details associated with the safe disposal and long term storage of spent nuclear fuel and nuclear waste materials.
A serious issue noticed during the associated public hearing was the number of unanswered questions over the adequate preparedness on part of the concerned local authorities during a credible scenario of uncontrolled radiation emission beyond the exclusion zone, as can be expected in a large size nuclear reactor site such as in Kaiga NPP, and in a scenario similar to what happened in Chernobyl (USSR) and Fukushima (Japan). It has to be emphasised here that none of the concerned authorities, including the local district authorities and AERC, have cared to respond to the associated concerns so far.
Hence, I am appealing to NDMA to consider every one of these concerns with all the seriousness they deserve, and to provide effective assurance to all the stakeholders about the adequacy/ efficacy of the safety precautions taken in this regard.
I notice with a lot of concerns that: whereas, the project proponent, through EIA, seem to have shifted the actual responsibility of off-site emergency measures to the Deputy Commissioner (DC), it should be emphasised that as the district administrator and also as the district magistrate, the DC has enormous and varieties of responsibilities even during normal times. 
It will be seen as the abdication of responsibility on part of the nuclear industry authorities in the country to expect a busy official, such as DC of a district in Karnataka, to appropriately react to a nuclear emergency unless he is ably assisted by a group of competent people, who are well trained and well equipped. EIA has no explanations in this regard.
In the overall context that the area around Kaiga APP is of difficult hilly terrain and is thickly forested, 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 numbers of all-weather roads are 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, nurses, community leaders etc. trained and provided with necessary equipment to detect any radiation leakage, and to take the necessary safety measures immediately? 
  •  Have a sufficient number of vehicles been 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/people?
If the difficult hilly terrain and thickly forested areas around Kaiga APP, along with a number of rivers and streams, are diligently considered, it can be credibly stated that even with the best intentions/ efforts of SDRF/NDRF, it will not be feasible to safely evacuate even 50% of the 32,000 odd people of the area in the case of a major nuclear accident. Hence, a major catastrophe for the welfare of the local population cannot be credibly ruled out.
NDMA should consider recommending to the Union government not to build additional nuclear power reactors
In this context of a credible and major catastrophe, the words "pro-active" and "prevention" in NDMA vision should indicate that there is a critical need to take all the associated issues into proper perspective, and arrive at rational conclusions.
In the engineering management parlance, the term "risk" can be defined as the product of "the probability of an incident/ event happening" and "cost/ implications of such an incident/ event". In the case of nuclear power reactors, whereas the nuclear power industry maintains that the "probability of an incident/ event happening" is very low, the "cost/ implications of such an incident/ event" can be humongous, as experienced in nuclear disasters at Chernobyl and Fukushima.
Hence, the most innocent question that can be raised in this context is: whether a nuclear power plant, which is credibly associated with not inconsiderable "risk" is essential to our society; certainly in the Indian scenario and even after witnessing multiple nuclear accidents/ incidents including two nuclear disasters at Chernobyl and Fukushima.
If certain analysis tools such as 'risk analysis'; 'costs - benefits analysis'; 'SWOT analysis' etc. are diligently deployed as economic decision making tools, the true costs to our country from a nuclear power plant, as opposed to meager benefits will emerge unambiguously. 
 Whereas the benefit from a nuclear power plant can be a few million units of annual electrical energy, the overall costs to the local communities and to the country as a whole can be humongous: huge capital cost, environmental and health costs, direct and indirect costs associated with any unfortunate nuclear accident, costs associated with the long term storage of nuclear wastes, costs associated with nuclear mines and nuclear ore processing activities etc.
As per many credible global estimates, and as per the high level estimates available in the public domain for the proposed Jaitapur Nuclear Power plant in Maharastra, the capital cost of a nuclear power plant can be many times more than the cost of a comparable size power plant based on alternative technologies such as solar and wind power plants. 
 Since these technologies are also benign, people friendly, and environmentally sustainable, there can be no credible reason as to why these technologies should not be the preferred options to meet the legitimate electricity demand of our people. Our country also has massive potential in such renewable energytechnologies, and it is also an official policy of the govt. to aim to be a global leader in harnessing these technologies. 
It is deplorable, hence, that there has been no credible official policy document so far from our authorities, to clarify why the nuclear power plants are continued to be built in different parts of the country despite the associated massive costs and risks to the true welfare of our people.
It must also be highlighted in this context, that the total nuclear power capacity in the country is less than 2% of the total power capacity in the country, and will only become increasingly irrelevant from the operational perspective of the power sector due to the fact that massive additions are being planned in other power technology sources, such as solar and wind power plants, in the next 10-15 years.
In this larger context, my detailed representation dated, 12th September 2019 addressed to the PM (as in the PDF file attached) has detailed discussions on various associated concerns, and on the vrey relevance of nuclear power to our country. 
 A diligent consideration of all the associated concerns should be able to convince NDMA to urgenty undertake a thorough review of the credible "risk" and massive costs associated with nuclear power reactors for the country in general, and with the proposed capacity expansion plan at Kaiga APP in particular.
I am of the considered opinion that in a densely populated and resource constrained country of ours, NDMA has a much larger and critical role to honestly try to avoid large scale disasters (certainly the avoidable technology related disasters such as nuclear reactor accidents), and that NDMA should not restrict itself just to undertake post-disaster relief operations. 
 Keeping in proper perspective all these risks, costs and concerns to our people, it can be credibly stated that the best option to prevent any associated disaster scenario from a nuclear power plant is to avoid building a nuclear power plant in the first place. 
Since there are many benign and attractive technological options to meet the electricity needs of our people, NDMA should seriously consider recommending to the Union government not to build additional nuclear power reactors until all the available alternatives are fully harnessed in the country; and also to safely decommission all the operating nuclear power reactors in order to prevent the humongous costs and concerns of any unfortunate nuclear reactor disaster to our people.
May I request that due diligence in this larger context is undertaken by NDMA at an early date, and the necessary advice is made to the Union govt. accordingly?



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