Koodankulam: A Court in the Supreme Contempt of its People


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P K Sundaram

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By P. K. Sundaram

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The Supreme Court’s verdict on Koodankulam rests on three hugely contested premises: the judges’ belief in the necessity of the nuclear energy for India’s progress, their faith in the country’s nuclear establishment to perform its role, and the judges’ notion of the larger public interest and the apprehensions of small sections which should make way for the country’s progress. Not only have the judges given judicial sanctity to these contestable propositions, but have also completely overlooked the Koodankulam-specific brazen violations of the government’s own norms, raised by the petitioners.

Broken justice

The Supreme Court’s judgement on Koodankulam would go in India’s history in line with the Narmada Dam verdict and other judicial pronouncement reflecting the inability of our post-independence democratic institutions to overcome the narrowly defined confines of ‘larger public interest’, ‘development/growth’ and ‘national conscience’.

Whose interests are larger?

While the petition filed by the Chennai-based environmentalist group Poovulagin Nanbargal presented specific concerns of safety hazards and violations of the government’s own norms in implementing the project, India’s growth and the assumed indispensability of nuclear energy for it is a recurring rationale in the Supreme Court’s final verdict. The judges have gone beyond the scope of the prayer and have extolled nuclear energy as essential for India’s growth, terming the ‘fears’ of people as misplaced. The judgement goes on to prescribe that ‘minor inconveniences’ must be tolerated in the larger interest of the nation.

People’s Movement is Emotional fear, Nuclear Establishment has the Expertise

The second paragraph of the judgement itself calls the people’s massive agitation in Koodankulam an “emotional reaction” to the setting up of the reactor. It almost mocks the people’s concern saying the “fears and unrest” might not have been thought of by Enrico Fermi who set up the first nuclear power plant. Since then, the judgement says, people have reacted emotionally when every new reactor is commissioned. The judgement goes on to add that the people’s concern was mooted even the constituent assembly when the Constitution was being drafted. Does this imply that nuclear energy in India should be regarded a fait accompli?

The judgement accepts the establishment’s narrative on nuclear energy in India unquestioningly.

  • The judgement extols the Atomic Energy Commission (AEC) as the repository of final authority on everything nuclear and the Atomic Energy Regulatory Board (AERB) as a competent regulator, glossing over its dependence on the AEC for funds and human resources and its being obliged to report to the AEC whose activities it is essentially mandated to regulate.
  • The verdict also reposes complete faith in the national policy on nuclear energy and the existing framework to control and regulate all radioactivity-related activities in India.
  • Under the title ‘National Policy’ (page 9) the judges narrate the evolution of India’s 20 nuclear power stations built over last four decades producing 4780 MWs today with a rare clinical coldness, without questioning the nuclear establishment’s claims and its performances in the same period, while under the same title on page 10, it mentions that renewable sources provide “small share” of our total electricity – 15%, which is actually 6 times more than the share of nuclear energy. 
  • In its overview of the global status of nuclear energy, the rapid downward trend of the industry post-Fukushima doesn’t find a mention – France produces 74.6%, US has 104 reactors, world had 439 reactors in 2007 producing 13-14% of total energy. The reality is, nuclear power produced just 11% in In 2011 and thedownward trend is expected to continue due to larger number of reactors ageing and lesser numbers being built today.
  • It doesn’t even question the NPCIL’s claims of producing 20,000 MW by the year 2020 and 63,000 MW by 2030.
  • Transgressing the scope of the petition, the judges have mentioned that “one of the reasons for preferring nuclear energy as an alternative source of energy is that it is a clean, safe, reliable and competitive energy source which can replace a significance of the fossil fuel like coal, oil, gas etc.” The judges have not bothered to see that each of these adjectives have been questioned and have led to review of national policies, including in France where a national energy transformation law is underway.

As the questions raised in the petition involved technical problems plaguing the Koodankulam project, the Court consulted the government’s experts – officials from the Nuclear Power Corporation of India Limited (NPCIL) and the Atomic Energy Regulatory Board (AERB). Unfortunately, no independent institutionalised expertise on nuclear issues exists in India outside the confines of the Department of Atomic Energy.  This led to a situation in which the Judges have no option than to believe the same official experts against whose refusal to acknowledge the risks was the petition filed. While this made the entire proceeding lop-sided in the first place, there was still scope for the judges to look into the glaring violations and specific risks in Koodakulam which do not fall strictly under nuclear expert issues.

The crucial issues of supply of sub-standard equipments by ZiO-Podolsk, violation of Coastal Regulatory Zone stipulations and Environmental Impact Assessment norms, lack of clarity on the crucial issue of spent fuel storage, non-compliance with proper mock evacuation drill required by the AERB norms, much larger population in the vicinity than stipulated etc. have either been glossed over or have been legalized post-facto.

Court validating a political deal?

The judgement mentions India’s civil nuclear agreement with the US in 2005 and then with France and UK in 2008 and 2010, and explains them as the govt’s effort give effect to the “National Policy for development” for which “India has entered into various bilateral treaties and arrangements with countries which have considerable expertise and experience”. It is a well known fact that the nuclear deal came from the US side and the energy justification was a later concoction to justify it. The integrated energy policy of 2006 came one year after the Indo-US nuclear deal. In fact, it was the nuclear establishment in India which was the first one to get surprised with the news of Indo-US nuclear deal in 2005. The deal was essentially about the US manoeuvring internationals institutions norms of the  NSG and the IAEA to legitimise India’s nuclear weapons and ensure its entry into global international commerce. India’s compulsory purchase of the French, American and Russian reactors was a price it paid to achieve this. Former AEC Chairman Anil kakodkar himself has admitted in the past that importing foreign reactors, with an embarrassingly low liability cap,  had to do with accommodating these countries’ interests.

 Nuclear Energy and National Policy

After enthusiastically elaborating India’s national policy on nuclear energy, the judges say, “it is not for Courts to determine whether a particular policy or a particular decision taken in fulfilment of a policy, is fair” (page 13). Precisely. The petition before the court nowhere sought to discuss the rationale or desirability of the nuclear policy, if at all India has one. The petition raised concrete questions about safety norms and their violations. Then why the judges have went on to declare nuclear energy is green, clean and essential for India’s development? The judges quote an old case in Lodon to undermine that its “only duty is to expand the language of the Act in accordance with the settled rules of construction”, and hence “we cannot sit in judgment over the decision…for setting up of KKNPP in Kudankulam in view of the Indo-Russia agreement”. Fine, but what about ensuring that the inter-governmental agreement between India and Russia is made public and the liability provisions within it be made compliant to the law of the land?

After the aforementioned introductory part, the SC verdict has two parts – the first deals with safety and security of NPP, International COnventiions and Treaties, KKNPP Project, NSF and its management and transportation, DGR, Civil Liabilities, DMA, CSA and other related issues. Part II deals with environmental issues, CRZ, desalination plant, impact of radiation on eco-system, expert opinions, etc.

In part I, the verdict seeks to find out whether the project has adequate safety measures. In doing so, it starts with elaborating the Safety Codes of the AERB (in 12 full pages), without questioning its institutional autonomy or making mention of the CAG’s report on the AERB in which it strips down the myth of AERB’s independence and its efficacy. Details of India’s international obligations and its adherence with IAEA safety norms, based on the AERB’s submission, take several pages more.

IAEA’s 2008 report emphasizing tripling of electricity supply by 2050 is highlighted by the judges. The IAEA’s contested claim of nuclear energy being a low-carbon electricity is adopted unquestioningly.

The verdict reposes its complete faith in “the safety and security code of practices laid down by the AERB, the IAEA and its supports so as to allay the fears expressed from various quarters on the safety and security of KKNPP”

The judges mention PUCL vs Union of India and others case of 2004, where the court upheld that the AEC deals with a sensitive subject. The veil of secrecy remains intact in 2013 even if the civilian and military nuclear facilities are separated as per the Indo-US nuclear deal.

Safety Issues:

Reading the Supreme Court verdict’s sections on Koodankulam’s safety is not much different than reading AERB’s or NPCIL’s stated policies on nuclear safety. Elaborate claims of safety standards and practices, but very little about whether these guidelines sufficiently address the specific questions raised by the protests, even less on how efficient and democratic these procedures are.

In the section under part-II titled “KKNPP  Project” the judges have looked into site selection procedures and site-specific vulnerabilities of Koodankulam. The judges come out convinced that Koodankulam is totally safe for the reactor project – having absolutely no potential of earthquake, Tsunami or other geological disturbances. The evidences presented by the petitioners about the area being geologically unstable and having a history of earthquakes, volcanism and karst have gone completely unheard.

Much attention has been given to the questions of safely storing Spent Nuclear Fuel (SNF) and finding a Deep Geological Repository (DGR) for KKNPP. These are generic issues plaguing nuclear reactors everywhere and globally the nuclear industry has been struggling to find the answers for several decades. Not surprisingly, there are ready-made and extremely tentative solutions: the NPCIL has agreed to find a repository to store nuclear waste and has given details of its long-term pursuits in this direction, and it has assured the court to safely story the SNF. The AERB’s code of “Management of Radioactive Waste” has been discussed at length, to be found sufficient to address the problem. Typically, Indian nuclear establishment does not acknowledge nuclear waste as waste, because it claims it will reprocess most of it for the second phase of its 3-phase  nuclear programme, to which even the judges have shown admiration. Lost of course is the fact that reprocessing leads to more harmful and long-term wastes and India’s phased nuclear program has been too far from becoming a reality. The judges note : “the experts feel that setting up of a DGR is not much of a technological challenge…but more of a socio-political issue”. The massive  disapproval of proposed waste repositories in the US and elsewhere was based on independent expert opinion is lost again. The verdict mentions a proposed DGR in the abandoned Kolar mines of Karnataka. Of course on this and other several important issues, the NPCIL retracting publicly from its position taken in affidavits filed in the SC had its own trail over last 6 months.

The judges have noted that the Koodankulam reactor has its Spent Fuel Pool inside the primary containment, with a capacity to store fuel equivalent to 7 years of full power operation of  the reactor. That the presence of SFP close to the reactor core complicated the accident in Fukushima and is a concern even today in Japan finds no mention, of course.

Fukushima never happened !

While the judges mention the post-Fukushima safety review ordered by the Prime Minister, they have failed to take into account the critiques of the whole process and the serious risks of relying on such an internal safety review without any independent supervision or assessment. On the 17 Koodankulam-specific recommendations, the court is assured by the AERB that the NPCIL will implement them satisfactorily. In the subsequent paragraphs, the verdict rhymes the nuclear establishment’s lullaby on radiation: We are exposed to radiation in our daily lives, cosmic radiation, radiation from earth’s crust, air travel, X0ray, CT-Scan, angiography, angioplasty etc etc.

In the section titled ‘Response to People’s Resistance’, the Supreme Court gives a sanitized, government version of the dialogue with people. It makes no mention of the fact that the 15-member expert committee appointed by the government did not even bother to meet the protesting people in Idinthakarai, declined from sharing essential safety-related documents with people and completely failed to address the questions raised by the movement. While this sham of a dialogue was on, the state government kept on piling false police charges, the local congress goons kept beating the protesters, the local media kept provoking against the movement leaders and none other than the PM indulged in maligning the people’s genuine struggle. The judgement quotes the government experts group’s conclusion at length and feels satisfied. It also takes no notice that the fact that the Ex-AEC Chief’s appointment as the head of expert committee constituted by the Tamil Nadu State Government subsequently reflected a seriosu conflict of interests.

Under the heading ‘Civil Liability for Nuclear Damage’, the judges in principle agree to the importance of strict liability in nuclear sector, but fail to address the Koodankulam-specific problem of opacity on liability issue. The Russian officials have been claiming they have an exemption from liability under the Inter-Governmental Agreement (IGA)

Discussion on Disaster Management Plan (DMP), the SC verdict elaborates about the guidelines of the National Disaster Management Authority (NDMA) on radiological emergencies and has pressed for better coordination between the NDMA, the DAE, and the state administration to ensure swift evacuation and management in case of a disaster. Much emphasis has been given on the need to spread awareness among the people about nuclear accidents, however, the brazen violation and bluffing by the NPCIL on disaster management receives no attention.

Although the Supreme Court quotes AERB’s norms on population near a reactor sites and specifically mentions that no public habitation should be there within 1.5 km radius of the reactor, it has failed to take into account the Tsunami Colony in Koodankulam where more than 2500 people reside at a distance of just 700- metres from the reactor. Also, the judges have held that the emergency preparedness plan (EPP) for KKNPP is adequate for around 24000 people in the 5 km radius called ‘sterilised zone’ while the norms stipulate not more than 20000 people. The catch here is, the even the 24000 figure used by the SC is taken from 2001 census, not the 2011 census!

The judges admit the importance of the mock-drills and off-site emergency exercises, but strangely caution that ‘such mock-drills are conducted to educate the public not to scare them away, but make them understand that the project is part of the national policy, participatory in nature, and hence we cannot remain as a nuclear-isolated nation’. This would only ensure that the nuclear establishment remains insulated from public scrutiny. The judges’ faith in the affidavit filed by the district administration on off-site emergency exercises flies in the face of reality.

In the last paragraphs of part-I, the Supreme Court judges have iterated their faith in NPCIL’s promise to fulfill its corporate social responsibility (CSR) – millions of rupees allotted for building schools, hospitals, roads and so on. From Tarapur to Rawatbhata to nearby Kalpakkam, local people have seen the realities of such promises.

The second part of the verdict, focused on environmental impacts, again starts with the need to look at environmental issues in the perspective of indispensability of nuclear power in the ‘national policy’ – nuclear energy has a unique position in the emerging economics in India, it is a viable source of energy and it is necessary to increase country’s economic growth !

The judgement in this part dwells elaborately upon the arguments presented by the both sides, but only to concur with the government that Koodankulam project does not violate environmental impact assessment guidelines as the project was notified in 1988, prior to enactment of EIA requirements in 1994! The flimsy affidavits filed by the NPCIL and the MoEF have found better audience with the Supreme Court judges. The court has elaborated upon the rather general and very lenient attempt of taking of environmental impacts in Koodankulam as per a letter written by the then Prime Minister, quotes the 1989 memorandum of the MoEF, the 1989 stipulations by the AERB for clearance, and finally with the MoEF’s letter dated 6 September 2001 in which it legalised the violations in the wake of 377.30 crores already spent on the project, feels confident that the environmental impacts have been taken care of and no violation of EIA stipulations have happened. In case of Coastal Regulatory zone (CRZ) clearance, it again validates the 1994 exemption given to the Koodankulam project.

The EIA reports for the proposed 4 other reactors in Koodankulam have used the EIA studies for Koodankulam 1 and 2 as base-line, which were prepared without a public hearing. Supreme Courts doesn’t find it worthy of objection.

Modifying the initial plan to take water from two nearby dams, construction of a desalination plant was started in 2006 in Koodankuiam. The petitioners had pointed out that the desalination unit would have its own hazardous environmental impacts and will also add to the overall pollution and hence had demanded a fresh EIA clearance. The court has said that desalination units are not listed under the 1994 EIA stipulations, so absence of such an EIA in Koodankulam is not a violation. Of course, the cumulative impacts also do not need any re-assessment then!

Similarly, the Supreme Court has brushed aside significant objections on CRZ clearance and post-factto legalization by TNPCB of the increased temperature of affluent water in Koodankulam. Under the heading ‘Sustainable Development and Impact on the Eco-System’, the verdict quotes elaborately from the Rolay Commission on Environment Pollution (UK, 1971), Stockholm Conference (1972), UNGA’s World Charter for Nature (1982), Rio Summit (1992), the UN MIllenium Declaration of 2000, UN Conference on Sustainable Development (June 2012) and so on, but only to conclude that “we have already found on facts that the KKNPP has been set up and is made functional on the touchstone of sustainable development and its impact on ecology has been taken care of following all national and international environmental principles” !

Larger Public Interests

Then the judges take it upon themselves to decide whether the claims of “smaller violations” of nearby population’s right to life under Article 21 of the Constitution should take precedence over production of energy, which is “of extreme importance for the economic growth of our country..to alleviate poverty, generate employment etc.” The judgement looks into various earlier cases of objections to ‘development’ projects on environmental and right to life grounds, and concludes that a balance between “economic scientific benefits” and “minor radiological detriments” has to be found. The pre-conceived notions of ‘development’ take over the judicial rigour and objectivity and in their hurry, the judges have done a grammatical faux pas: “Larger public interest of the community should give way to individual apprehension of violation of human rights and right to life guaranteed under Article 21″! We can over look the grammatical blunder of our judges, but what about terming the massive protests by thousands of people in Koodankulam, run for over 25 years in a thoroughly peaceful manner, as ‘individual apprehension’? Who is the ‘larger community’? Do the interests of the farmers, fishermen and poor people of India do not form the ‘larger public interest’?

The judges have gone ahead to claim that apprehensions of far reaching consequences of radioactive effects has “no basis”! The say: “Nobody on the earth can predict what would happen in future and to a larger extent we have to leave it to the destiny….Apprehension is something we anticipate with anxiety or fear, a fearful anticipation, which may vary from person to person.” The Court goes by the “expert opinions” of MoEF, EAC, TNPCB, Report of IOM, Report of Engineers India Limited, NEERI’s EIA etc and concludes that all expert bodies are unanimous that in their opinion KKNPP has fully satisfied all safety norms.

Justice Dipak Misra in his prologue emphasizes the need to “march ahead with life allaying all apprehensions with a scientific mindset accepting the nature’s unpredictability to survive on the planet earth on the bedrock of the doctrine – survival of the fittest”. He again goes on to describe how elaborate the DAE’s guidelines on nuclear safety are, and concludes that ‘all possible measures have been taken to avoid any kind of calamity’. He goes on to quote extensively from the IAEA’s 1994 Convention on Nuclear Safety and the Joint Convention on the Safety of Spent FUel Management and on the Safety of Radioactive Waste Management 1997, to which India is not even a signatory, to appreciate the “world wide concern for public safety”. He again quotes in extenso from the AERB’s post-Fukushima Safety Review of KKNPP. However, an unquestioned faith in the nuclear establishment about adequacy of these recommendations and the establishment’s sincerity to implement leads to plain judicial reassurances.

Justice Misra looks into proportionality of safety vis-a-vis the necessity of nuclear energy development. While accepting the need for ensuring safety for present and future generations, he holds that ‘generation of nuclear energy is a necessity in a progressive modern state’ and ‘promotion of development and protection of the environment have to be harmonized’. Besides other cases, Justice Misra cites the Narmada case and quotes that “In a democracy, welfare of the people at large, and not merely of a small section of the society, has tobe the concern of a responsible Government.”

In the final judicial directions, the judges have asked the NPCIL to file a report before the Supreme Court before the final commissioning, certifying that each and every aspect of safety including environmental impacts, have been taken care of. For the periodical safety maintenance and reviews, safety of the spent nuclear fuel during transport, radioactive discharge to the atmosphere, compliance with the 17 post-Fukushima recommendations, and adherence to the NDMA guidelines, the court has directed the NPCIL, AERB, MoEF, TNPCB and other concerned bodies ensure strict compliance, but has essentially reposed faith in their efficacy and sincerity. The Supreme Court has ordered that a Deep Geological Repository should be set up at the earliest so that SNF can be transported from the nuclear plant to the DGR.

Withdraw Criminal Cases Against Protesters: The Supreme Court has directed to withdraw al criminal cases filed against the agitators in Koodankulam and to restore normalcy and peace.

The Supreme Court’s verdict rests on three major premises: the judges’ belief in the necessity of the nuclear energy for India’s progress, their faith in the country’s nuclear establishment to perform this role, and the judges’ notion of the larger public interest and the apprehensions of small sections which should make way for the country’s progress. All three of these are immensely contested propositions. But not only have the judges given judicial sanctity to these contestable claims, but have also completely overlooked the Koodankulam-specific brazen violations of the government’s own norms, raised by the petitioners.

In retrospect, the struggling people of India would find approaching to the Supreme Court in such matters pointless, and counter-productive, as the courts themselves are part of the system which has failed to address the widening gap between the aspirations and lives of the deprived masses and the mainstream notions of ‘larger public interest’. Prayers before the judiciary on such matters ends up legitimising the same ‘experts’ and disastrous notions of progress that the people have been fighting against.

DOCUMENTS:

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Re-posted from DiaNuke.org

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Koodankulam: Shoddy equipment develops leaks


Sam Rajappa.

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By Sam Rajappa

Posted on February 17, 2013, in The Island

Kudankulam Protest rally - 01

Demonstrators near the Kudankulam nuclear power project (File Photo)

ACCORDING to the Department of Atomic Energy and the authorities of Nuclear Power Corporation of India, the loading of uranium fuel rods at the 1,000 MWe-capacity first unit of the Koodankulam Nuclear Power Project was completed on 2 October last year, but has not produced a single unit of electricity so far. Critical equipment supplied by Atomstroyexport of Russia, building nuclear reactors abroad, were found to be shoddy and have developed leaks even before commissioning of the plant. The financial statement released by Atomstroyexport shows its losses have doubled in the last year and it is on the brink of bankruptcy. Russian engineers at the Koodankulam plant site have not been able to plug the leaks. In a desperate attempt to commission the plant, as Prime Minister Manmohan Singh has made it a prestige issue, NPCIL has flown in technicians from Croatia and Germany to carry out repairs in the Russian designed and erected plant. NPCIL claims to have spent an excess of Rs. 4,500 crore on the non-functioning power plant. The People’s Movement Against Nuclear Energy has threatened to lay siege on the Koodankulam nuclear complex in a non-violent manner if the Centre commissions the first unit in haste and secrecy without attending to its safety requirements, and sought a White Paper on the KKNPP and its reactors from the Centre. It was turned down.

An official statement issued by NPCIL on 25 January said the Atomic Energy Regulatory Board has given permission to “repeat the full systems test at the first unit.” One needs to repeat a test only if it failed in the first instance. NPCIL’s desire to gloss over its failure and make it seem as if the ‘permission’ is a hard-won victory is understandable. But why is the AERB condescending even after RK Sinha, chairman of Atomic Energy Commission, had said that “there are some system parameters like flow, pressure, temperature that need to be maintained within particular values.” During the first hydro test conducted last December, certain valves did not behave the way the manufacturer claimed they would. These valves were opened, repaired, and some components replaced. The fact that brand new valves malfunctioned raises questions about the quality of equipment supplied. Identification of defective valves at this late pre-commissioning stage suggests that the quality of assurance of individual components was deficient.

In February last year, Russia’s Federal Security Service arrested Sergei Shutov, procurement director of Rosatom subsidiary Zio-Podolsk, on charges of corruption and fraud. Zio-Podolsk is the sole supplier of steam generators and some other key components for Russian nuclear reactors worldwide, including India. Shutov was charged with using cheap Ukranian steel blanks in nuclear reactors. NPCIL should reveal whether the leaky valves were supplied by Zio-Podolsk. A PTI feature issued in July 2011 reveals, quoting DAE sources, that the Koodankulam plant was expected to be commissioned in March 2009, long before protesters held up work on the project for nearly six months, but was delayed because of difficulties experienced in receiving equipment from Russia “in sequential order.” The article says: “The designers discovered that several kilometers of power and control cables in the reactor were missed after the completion of double containment of the reactor.” The problem was rectified after the cables meant for power supply to instrumentation in different buildings were incorporated by breaking open the concrete walls in the containment domes and was sealed again bringing the cables from the switch yard to inside. Breaking open and resealing the containment dome is unprecedented in nuclear power industry.

As the Manmohan Singh government is determined to unleash all kinds of atrocities on peaceful protesters against the shaky Koodankulam plant like filing 325 cases including sedition, waging war on the Indian State and on other serious sections of the Cr PC and IPC with 5,296 named as accused and 221,483 unnamed accused at one police station alone near the plant site, PMANE has taken up the issue with Congress vice-president Rahul Gandhi who had earlier reached out to the tribal people opposed to Vedanta Resource’s Rs. 4,500-crore bauxite mining project in Orissa’s Niyamgiri Hills. Rahul had then said: “True development takes place by respecting the interests of the poor,” and offered to be their sipahi in Delhi. SP Udayakumar, coordinator of PMANE, in a letter to Rahul, said if the Congress did not respect people’s power, democracy and peaceful struggles, and starts the Koodankulam plant forcibly, it would prompt the voters at least in Tamil Nadu and Kerala to shun the Congress.

Unmindful of the people’s fears about the breaking open and resealing of the dome of the Koodankulam plant, the AERB, DAE and NPCIL remain tight-lipped. Even a small mishap in a nuclear facility will have the potential to destroy millions of people in our densely populated country. In a recent report, the Comptroller and Auditor-General of India has passed strictures on the ‘toothless’ AERB for not even ensuring nuclear and radiation safety in any of the atomic installations in the country. The long-awaited Nuclear Safety Regulatory Authority Bill, tabled in the Lok Sabha on 7 September 2011, ostensibly to bring about much needed independence and transparency in administering safety of nuclear operations, remains a non-starter. According to A Gopalakrishnan, former chairman of AERB, the Bill fails to serve any of its laudable objectives in its present form.

The Bill seeks to establish a Council of Nuclear Safety to be chaired by the Prime Minister and will have as its members five or more Cabinet ministers, the Cabinet Secretary, chairman of the AEC and experts nominated by the Union government. The CAS will constitute two search committees, one to select the chairperson and the other to select members of the NSRA. The CNS is empowered to create an Appellate Authority to hear any appeals on any order or decision of the NSRA. The same Appellate Authority will also decide on appeals from the government against the NSRA. What the government tries to do under this Bill is to create a high level council under the chairmanship of the Prime Minister to control and curb the freedom of action of the NSRA. Clause 20 of the Bill stipulates the NSRA should function in a manner consistent with the international obligations of India.

If the NSRA were to find the equipment supplied by Russia to the Koodankulam plant substandard and do not conform to safety norms, the regulatory body dare not act for it would be contrary to “India’s international obligations” Prime Minister Manmohan Singh has promised unilaterally to his Russian counterpart while on a visit to Moscow in December 2011.

The same clause also says the NSRA “shall not interact with bodies outside India without the prior approval of the government.” The subservient nature of the proposed NSRA has been made abundantly clear in Clause 48(1) which says: “the Central government may, by notification, supersede the regulatory authority for such a period not exceeding six months. Upon notification, the chairperson and members of the NSRA shall vacate their offices as such; … all the powers, functions and duties shall, until the authority is reconstituted, be exercised and discharged by the Central government.” The NSRA can never be independent unless the appointment of its chairperson and selection of members of the regulatory authority as well as suppression of the NSRA are left to Parliament and not to the ruling party of the day. (The Statesman/ANN)

Re-posted from The Island

About the author:

Sam Rajappa

Sam Rajappa is a journalist with over five decades experience in media. He is The Weekend Leader’s Consulting Editor. Sam started his career in journalism in 1960 as a sub-editor with the Free Press Journal in Bombay. In 1962 he joined The Statesman in New Delhi and later moved to Chennai. He was associated with the paper till 2008. In 1980, he took a year’s sabbatical from The Statesman to set up the South Indian network of India Today, and worked as their South India bureau chief based in Bangalore. Again, he took a short break from the paper in 1996 to launch The Andhra Pradesh Times, an English daily published from Hyderabad, as its founder-editor. For about fifteen years, since 1980, Sam was also the BBC’s South India correspondent. He was an adjunct faculty member of the Chennai-based Asian College of Journalism from 2001 to 2007 and later served as Director of The Statesman Print Journalism School, Kolkata.

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News: Nuclear Power Plants Will Be Located in any Indian City


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Myself By T.V. Antony Raj

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Protest at Kudankulam

Protest at Kudankulam

In the midst of a stormy debate on atomic energy, Indian scientists are now designing nuclear reactors that can be positioned in the middle of a metropolitan, or any large city. Construction of the reactors might possibly get underway within the next five years.

Exclusion zone

Distance from a Nuclear plant

Distance from a Nuclear plant

A conventional nuclear plant requires an exclusion zone that extends for 1.6 kilometers radius around the reactor, directly under control of the nuclear power plant administration. It is followed by a low population sterilized zone up to five km from the reactor where the growth of population is limited by administrative control. And finally, an emergency planning zone within a radius of 16 km from the reactor The outermost zone defines the minimum distance to high population centers.

Safety Features of AHWR Reactor

The much-delayed 300 MW Advanced Heavy Water Reactor (AHWR), the latest Indian design for a next generation nuclear reactor, now on the design table for close to a decade will burn thorium in its fuel core. Globally, thorium is three times more abundant than uranium.

The scientists designing this third stage in India’s 3-stage fuel cycle plan claim that it has several inbuilt safety features to allow the plant to be located even in densely populated areas.

Officials said these safety features would it make it possible to meet the next-generation safety requirements like three-day grace period for operator response, elimination of the requirement of an exclusion zone beyond the plant perimeter, hundred-year life duration, and high-level of fault tolerance. Designed with a high-level of fault tolerance, the AHWR provides for a much greater immunity even from an insider threat.

Mr. Shiv Abhilash Bhardwaj, director (Technical), Nuclear Power Corporation of India Limited (NPCIL) confirmed this. He said: “The AHWR has a number of inbuilt safety features that would require very little exclusion zone and can be built right in the heart of the city.”

He further said that they expect to start construction of the AHWR during the 12th Plan period.

A site for building the AHWR, designed by a team of nuclear scientists led by former Atomic Energy Commission chairman Mr Anil Kakodkar and incumbent Mr Ratan Kumar Sinha, is yet to be finalized.

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Stop Kudankulam fuelling, lives are at stake!


By Dr. A .Gopalakrishnan (a past chairman of the Atomic Energy Regulatory Board)

English: Internationally recognized symbol. De...

The government, through its Department of Atomic Energy (DAE), the Nuclear Power Corporation Limited (NPCIL), and the Atomic Energy Regulatory Board (AERB) is racing to bring the Kudankulam Nuclear Power Project, Unit-1 (KNPP-1) to full-power operation at the earliest. The questions predominantly troubling the conscientious public today are simply these: Is the Kudankulam Unit-1 ready for introduction of nuclear fuel assemblies into its core (‘fuelling’), having fully completed all the safety modifications and additions recommended by AERB’s Post-Fukushima Committee to Review Safety of Indian Nuclear Power Plants? What other mandatory, pre-fuelling safety-related tasks such as conducting proper emergency drills in villages within a 30 km-radius of the reactors remain? What are the serious implications to public safety if NPCIL and AERB move forward with fuelling activity and bring this reactor to its full power of 1000 MWe in the current state of inadequate and incomplete safety status?

On some of the glaring defaults of the current actions of the DAE, NPCIL and the AERB vis-à-vis KNPP-1, there are three Special Leave Petitions (SLPs) currently before the Supreme Court of India. The next hearing of one SLP that seriously pleads for stopping fuelling activity is set for September 27. As early as on March 26, 2012 , a writ petition (no. 8262) was filed in the Madras High Court for a direction against the DAE, NPCIL, AERB and others to implement all the recommendations of the AERB’s Post-Fukushima Report before fuel-loading is started. In response, the AERB counsel informed the court , “— that before initial fuel loading is done, the compliance of all the requirements under Annexure-8 (of the AERB report) will be ensured by the AERB and it is only after its satisfaction any direction (for loading fuel) will be given—” . Subsequently , the High Court decided to reserve its orders on August 2, 2012 , pending detailed judgement to follow.

n the interim, since the court had not imposed any stay on actions by NPCIL and AERB, chairman, AERB, used this opportunity to issue a clearance for initial fuel loading of KNPP-1 on August 10 after reviews by their internal committees. The original petitioner then filed yet another writ petition (no. 22253) in the Madras HC on August 13, challenging the fuel-loading clearance given by AERB, even while 11 out of the 17 safety recommendations of the AERB’s Post-Fukushima Report still remained to be implemented. AERB, in reply to this writ petition, submitted two affidavits, first one on August 18 and another on August 22.

he post-Fukushima evaluations by an independent AERB committee, headed by a past chairman of the AERB had recommended 17 safety upgrades in Annexure-8 of its report. The committee, however, did not sort these on the basis of relative importance, urgency or priority. The sense you get from this report is that all 17 corrective steps are equally important and AERB must insist on all of them being fully implemented and tested before fuel-loading is permitted. This is consistent with the affidavit earlier submitted to the Madras HC by Mr R. Suresh Kumar, counsel for AERB, “ — that before initial fuel loading is done, the compliance of all the requirements under Annexure-8 will be ensured by the AERB and it is only after its satisfaction that any direction will be given—–” .

However, in their affidavits to the same court on August 18 and 22, AERB reversed its stand by stating, “—recommendations in Annexure-8 of the Post-Fukushima Report were considered (by the internal AERB committees) during review of the application for fuel loading submitted by NPCIL. The review indicated that KNPP-1 has adequate safety measures against external events — In order to further enhance safety , as an abundant measure , some additional safety enhancements proposed by NPCIL were reviewed in depth and accepted for implementation in a phased manner.”

“Based on the review and resolution of NPCIL submissions, AERB agreed for short-term (less than six months) and long-term ( less than two years) implementation of the Post-Fukushima recommendations from the date of the fuel-loading clearance”.

Ultimately, the Madras HC did not agree with the plea of the protesters for full implementation of Annexure-8 safety steps before fuel loading is initiated and the matter is now being heard by the Supreme Court. Even as the Supreme Court hearings are going on, the NPCIL and the AERB are already loading the nuclear fuel into KNPP-1.

What the AERB has done is a total volte face of its earlier stated positions in the Madras HC, and contrary to the spirit and recommendations of the AERB Post-Fukushima Safety Evaluation Committee.

This has happened because the DAE, NPCIL and AERB appear to be under the direct control of the PMO on the Kudankulam issue, and none of them dares to take any decisions on their own.

The PM, is for months accused in the national and international press for India’s policy paralysis, the dwindling performance of the power sector, and for substantial slippage in the execution schedules of many major projects. During his last two visits to Russia, the PM promised expeditious completion of KNPP-1&2. The local protests at site have put a monkey wrench into his promises and timetable. PM and his PMO consider their face-saving to be more important than the possibility of imperiling the lives of people living near KNPP-1, and appear to have clearly instructed the DAE-AERB combine to rush through with commissioning the plant. The subservient DAE and AERB seem to be complying with his directions.

In this hurried approach to starting the KNPP-1 project, what essential safety precautions are the NPCIL and AERB tossing by the wayside? As per current plans, the reactor will be operated at least for the first two years or more at the full power level of 1000 MWe, without its primary containment being assessed for its ultimate load-bearing capacity; without the availability of a portable diesel-powered unit with sensors and instrumentation to monitor essential safety parameters in case of a total blackout; in the absence of a set of mobile self-powered pumping set for emergency area use; without rectifying the serious inadequacies in instrumentation for independent monitoring of plant status during major accidents; and without the addition of mobile back-up power units like air-cooled diesel sets. Why each of these actions should take as long as 24 months to complete is unimaginable, but these actions have to be indeedexpedited, since they are all essential for mitigating the consequences of a major accident.

The AERB committee has also strongly recommended the urgent installation of an additional seismically-qualified 8,000 cubic-meter capacity back-up water storage tank as an alternate source for use under emergency situations where such actions as injection of borated water into the core and into the spent-fuel pool, charging water into the steam generator secondary side, etc will require excessive amounts of water. The already provided emergency water-storage facility has not been seismically-qualified and may not withstand moderate earthquakes. This anomaly has to be urgently rectified through analysis and repair. This existing storage was also found to be inadequate in holding capacity , for removing decay heat for a period of a minimum one week . This too is to be rectified. In case of a beyond design basis accident (BDBA), the emergency operating procedures to be used are still to be formulated and documented, to help impart training on BDBA to the operating staff.

It is more than 16 months since the Fukushima accident occurred and NPCIL has not even started planning for these procedures. Each of the above tasks is put in for “short-term” completion, namely, within the next six months. I doubt whether a satisfactory completion of many of these tasks can be achieved in six months, each may take more like one year at least.

As it stands, the important point to note is that NPCIL and AERB are NOT going to carry out any of the short or long-term tasks mentioned above, before the reactor is fuelled and brought to 1000 MWe power level. This approach is totally unacceptable from the safety point of view. Whether these 17 safety corrections are implemented or not, the probability of a major accident will remain more or less the same. But, ALL these safety corrections are necessary to ensure that the mitigation of the consequences will be far more acceptable with the corrections implemented than without, and these safety corrections will provide a distinctly safer environment for populations around the KNPP-1. Therefore, ALL the above-mentioned long-term and short-term safety corrections recommended by the AERB committee must be completed before the reactor is fuelled. Whatever fuel so far loaded into the core can be taken out safely and stored for future use.

The author Dr. A. Gopalakrishnan is a past chairman of the Atomic Energy Regulatory Board (AERB).

Reproduced from DNA

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PMANE’s Open Letter to Jayalalitha – ‘Lets walk the talk ‘


tvaraj:

Most of the people here in our area have been praying to Our Lady of Lourdes at Idinthakarai and to the Sage Vishwamitra in one of his rarest temples in India near Koodankulam with the solemn hope that these divine forces would save them from nuclear threats to their land and the sea. They believe that from Gorbachev and Rajiv Gandhi who initiated the KKNPP to the Russian engineers and scientists who designed the Koodankulam reactors have met with misfortunes. It is only natural for people to turn to supernatural forces when their political energies are dissipated and actions discouraged by the vested interests.

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Originally posted on kracktivist:

August 20, 2012
 
The Struggle Committee
People’s Movement Against Nuclear Energy (PMANE)
Idinthakarai & P. O. 627 104
Phone: 98656 83735
 
The Honorable Chief Minister
Government of Tamil Nadu
Fort St. George
Chennai 600 009
Fax: 044-24992255, 25671441, 28133510
 
Honorable Madam:
 
Greetings! As we have completed a whole year struggling against the Koodankulam Nuclear Power Project (KKNPP), we would like to initiate a fresh round of dialogue with you.
 
As you know, the Government of India and the Department of Atomic Energy (DAE) have not shared any basic information with us about the KKNPP. Even after the Central Information Commission (CIC) has instructed them, they have not shared the Site Evaluation Report (SER) and the Safety Analysis Report (SAR) with us. They have not heard our opinions or allayed our fears and concerns about the lack of fresh water resources, the changes in the design…

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Press Release – PMANE’S RESPONSE TO NPCIL’S SER – Koondankulam


People’s Movement Against Nuclear Energy (PMANE)        May 24, 2012Idinthakarai & P. O. 627 104Tirunelveli District, Tamil NaduPhone:             98656 83735      ;             98421 54073

koodankulam@yahoo.com

pushparayan@gmail.com

Press Release

[1] As per the Decision No. CIC/SG/A/2012/000544/18674 dated 30.4.2012, the Central Information Commissioner ordered “to provide an attested photocopy of the Safety Analysis Report and Site Evaluation Report after severing any proprietary details of designs provided by the suppliers to the appellant before 25 May, 2012.” The CIC has stated categorically that “if the said reports have details of designs of the plant which are specially provided by the suppliers,” “the PIO can severe such design details which have been provided by the supplier as per the provisions of Section 10 of the [RTI] Act.”

[2] The NPCIL in its reply to the CIC argues that the Safety Analysis Report (SAR) “is a ‘third party document’ and therefore, without the prior consent of the third party, the same cannot be shared with anyone.” Although they are holding the SAR in a ‘Fiduciary Capacity,’ the NPCIL has said it is “ready and willing to show the copy” of SAR to the CIC. But they cannot share it with the people of India. Obviously, the NPCIL is more interested in the safety of the Russian company and the Russian benefactors but not in the safety of the people of India.

[3] The Central Public Information Officer, Shri S. K. Shrivastava, has sent “the copy of Site Evaluation Report for KKNPP 1 & 2” with the cover letter No. NPCIL/VSB/CPIO/620/KKNPP/2012/769 dated May 17, 2012.

Physical Shape of the so called SER:

The so-called Site Evaluation Report (SER) consists of twelve (12) pages of hardly-legible typed-material with no cover page, no authorship, no ownership, no publisher, no date, no index, and no head or tail. If the print quality of the so called SER is anything to go by to assess the standard of the overall Koodankulam nuclear power project, we have so much to worry about our and our country’s future. You can hardly read a word and rarely decipher a number. Maybe that is the way NPCIL prepares its important public safety reports so that no one can and will read, understand, discuss, debate and ask more questions.

Moreover, the so called SER mentions the Soviet Union in several places and it proves that the report is also quite old and outdated. Common sense tells us that this is certainly not the original or complete ‘Site Evaluation Report’ for KKNPP 1 and 2. And if it really is, then Indian citizens have something serious to worry about. In all probability, what we have received is some loose old notes of the NPCIL hurriedly put together to meet the CIC deadline and to mislead the public. It is very strange that the SER of India’s first largest mega nuclear complex that may allegedly house six to eight large imported reactors is 12 loose A-4 sheets. It is unbelievable that an ambitious India-Russia joint project built with a whopping outlay of Rs. 14,000 crore has such a lackadaisical site evaluation study.

In the so called SER that has been sent to us, pages 1, 2, 3 and 13 have been expunged without any explanation. It is unlikely that this report may have “details of designs of the plant.” It gives rise to a suspicion that the NPCIL still hiding some crucial public safety-related information from the Indian public. On Page 4, the last paragraph mentions “the site selection committee” and “[t]he present committee” without mentioning the number of members or their names. It is unclear why the NPCIL is trying to hide this vital and relevant information.

Startling Revelations in the so called SER:

[i] Pechipari Water Will be Taken

The so called SER records on Pages 6-7: “In order to enhance additional reliability for water supply, which is essential for functioning of various safety systems of the reactor, intake well at Pechiparai Dam should be provided at lower elevation than the minimum draw-down level of the reservoir. However, it should be ensured by proper management of water distribution that the water level is maintained above this minimum level.” On Page 11, the SER discusses “Fresh water for make-up and domestic use” and establishes that it is “Assured by State Government. One pipe line from Pechiparai dam (at 65 km) to be laid.” Indeed two pipe lines have already been laid from the tail end of the Kuzhithurai Tamirabharani river along the Kanyakumari district coast and from a location some 5 kms away from the Pechiparai dam through Nagercoil town. The NPCIL authorities simply parrot the unserious assertion that they would not take water from the Pechiparai dam, and the Government of Tamil Nadu ignores our long-standing demand of passing an Assembly resolution against taking the Pechiparai water. As a matter of fact, the Tamil Nadu government has recently allotted nearly some Rs. 5 crore to desilt the dam and maintain it.

 [ii] No Evacuation Routes Planned or Prescribed

The so called SER claims on Page 8: “At least two evacuation routes from plant site during an emergency should be provided.” It established on Page 16: “3 routes exist for possible evacuation. Schools and other public buildings exist for adequate temporary shelter, Nagercoil (30km), Tirunelveli (100km), and Tuticorin (100km) can provide communication, medical facilities and administrative support.” But there is no discussion about the escape routes, the condition of these roads, the status of the relief shelters and so forth.

[iii] Possible Future Expansion

Under Topography, the so called SER asserts: “Sufficient land available for future expansion.” But the NPCIL officials keep saying that they will not take more land for the KKNPP.

[iv] Incomplete and Incoherent Info on Hydrology, Geology, Oceanography and Seismology Aspects

All these important issues are very briefly mentioned in a Table with cursory information and without any in-depth analysis.

  • Tsunami is explained away by saying “Not significant as per preliminary report of CRPPS.”
  • As far as seismotectonic environment is concerned, the report asserts simply that “No active fault within 5 km. Site is seismic zone II as per IS-1893; 1984.”
  • The report says on Page 14: “A lime stone quary of about 70 acres falls within the sterilized zone. The lease for this area expires in 1994. Termination of the lease beyond the period has been requested.” In fact, this quarry has functioned until very recently.

Important and relevant issues such as Karst in the area, the slumps in the sea and the recent mega earthquake in the Indian Ocean have not been mentioned or discussed.

[v] Radioactive Waste Details

Solid Waste

The so called SER says:

  •  “160-180 m cu per year of cemented waste including spent absorption materials, 40 m cu/yr of compacted waste and 5 m cu/yr of cemented ash will be generated from one reactor.”
  • “Low level solid waste to be buried within exclusion zone in leak-proof RCC Vaults/trenches/tile holes.”
  • Spent Fuel: “Each unit layout can store spent fuel of 5 reactor years in the spent fuel pool located inside the containment.”

Liquid Waste Dumped into the Sea

According to the SER, the liquid waste is “[t]o be diluted to 2x10E-7 micro Ci/l when discharged into the sea.” So it is clearly established that the radioactivity in the liquid waste of 6000 mCu/year from two units will be removed in the Ion exchange resin and as evaporator concentrate. It will be further diluted by condenser cooling water to meet the AERB limits and discharged into the sea.

Gas Release

The daily releases of gaseous discharge from KKNPP 1 and 2 will contain noble gases, I-131, long-life nuclides and short-life nuclides.

Thermal Pollution

According to the SER, “Depth of sea water and large dilution due to sea will avoid thermal pollution.”

[vi] Population

The so called SER asserts wrongly that there are no center of more than 10,000 people within 10 km radius zone and no center of more than 100,000 people within 30 km radius zone.

There is hardly any mention of desalinations plants, the transportation of the nuclear waste and other crucial issues. To sum up, this SER reads like a practical joke being played upon the innocent people of southern Tamil Nadu and southern Kerala. The PMANE rejects this so called SER and demands the NPCIL to share the real, complete and updated Site Evaluation Report with the people of India along with the Safety Analysis Report as per the orders of the CIC.

The Struggle Committee

People’s Movement Against Nuclear Energy (PMANE)

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Work continues at Kundakulam Nuclear plant as does police crackdown on protesters


Originally posted on kracktivist:

KoodankulamNuclear Power Project site, commissioning expected by the end of May

Jeemon Jacob
Thiruvanthapuram, 2 nd April 2012

Work at the Koodankulam Nuclear Power Project site continues to be on a fast track, and according to sources the plant will be ready to commission within eight weeks. According to an official working at Koodankulam Nuclear Power Project site, the commissioning of the plant is expected by the end of May. Scientists and officials had reviewed the progress of the project last week. “Our scientists and technicians are working over time and we will be able to complete the project in time,” said the official who wished to remain anonymous.

Meanwhile, the government crackdown on anti-nuke protesters continues. The Madurai Passport Officer has directed PMANE convener Dr SP Udayakumar to surrender his passport as a criminal case is pending against him. On Friday 30 March, officials from the intelligence bureau…

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PRESS RELEASE By Prasanth Bhushan : Thiruvananthapuram April 1st 2012


Human rights activist and Team Anna core member Prashanth Bhushan is a Senior Supreme Court lawyer practicing in Delhi and a social activist. He is the son of lawyer and former Law Minister of India Shanti Bhushan.

PRESS RELEASE By Prasanth Bhushan : Thiruvananthapuram April 1st 2012

I visited Koodankulam yesterday to meet the people fighting against the nuclear power plant to see for myself what is happening there. It was very impressive and inspiring to see the discipline and determination of the thousands of people, particularly women and children who were sitting at the dharna site at Idinthakarai.

It is unfortunate and condemnable that the govt. and the local police administrators have arrested hundreds of these protestors and instituted hundreds of cases against them, making absurd charges of sedition, naxalism etc against these peaceful protestors.

Nuclear power is the most expensive way of generating electricity apart from being extremely hazardous, as has been pointed out by a number of independent experts such as Dr.E.A.S.Sharma (former power secretary), Dr. A.Gopalakrishnan (former Chairman, AERB) among others. Apart from the risk of a catastrophic accident as happened in Chernobyl and Fukushima which renders tens of thousands of square kilometers land uninhabitable and uncultivable, there are very serious problems of storage of spent fuel and safety of the nuclear fuel.

That is why most countries of the world, especially developed countries have abandoned nuclear energy and are phasing out their existing plants. Japan has shut down all except one of their nuclear reactors after Fukushima which were generating 34% of their electricity.

Yet, strangely India is embarked on a massive expansion of nuclear power, going to the extent of seeking to import plants like Jaitapur which are untested and will cost 2 lakh Crores (for a 10000 MW plant) which makes it more expensive than even solar or wind energy. It is being done for the benefit of foreign nuclear power plant manufacturing corporations at the behest of their governments? In the absence of any transparency in these deals will the people not be justified in suspecting that kickbacks are motivating these decisions?

In the case of Koodankulam, there are several additional problems which make the site unsuitable for setting up a nuclear plant. An independent expert committee has pointed out that there is considerable scientific evidence of volcanic activity in this area and it is also an earthquake prone zone which can have a Tsunami as well. There are several populous villages in the immediate vicinity as well as a colony recently established by the government for rehabilitating the Tsunami victims. Also, most ominously, the NPCIL has not complied with the AERB’s condition that the plant should have a secure source of fresh water and storage for 60 days requirement of fresh water for cooling the fuel rods.

The project was given environmental approval many years ago without any public hearing and without considering these serious issues. All this becomes even more serious in the absence of setting up of an independent regulatory body for nuclear energy. The AERB continues to function as a department of the Atomic Energy Commission. Even the 3 prior safety audits of existing plants conducted by the AERB in ’79, ’86 and ’95 which pointed out serious problems of safety with the existing plants have not been put out in the public domain despite the Prime Minister’s promises.

The Koodankulam protestors are therefore fully justified in agitating against the plant. It is imperative that the government respects their sentiments and fears and immediately suspends work at the plant. It must constitute a credible independent expert committee to examine all the safety issues which have been raised, in a transparent manner with public hearings and not resume work on the plant till all safety issues have been credibly addressed. All the arrested agitators must be released and the cases against them withdrawn. All plans of setting up new nuclear plants must be suspended till an independent safety regulator is set up and safety audits of all existing plants and proposed plants is conducted in a transparent manner.

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