My letter on Koodankulam Nuclear power plant in The Hindu (09-03-2012)
The Fukushima accident serves as a glaring reminder for the Kudankulam anti-nuclear plant activists that states do not have solutions for serious social, economic and ecological crises of our time (March 8). On the contrary, governments are making disasters, not unmaking them, risking our collective future for their own short-term gains. The legacy of Chernobyl or Fukushima proves that nuclear power is not without enormous risk. Though the government is fond of nuclear power because it has already invested crores in the industry, we are ill-prepared for the coming of nuclear power. A nuclear plant gives us 40-50 years of cheap, clean energy, followed by 1,00,000 years of waste management. The government can also think of an alternative way to promoting renewable energy.
In response to the article “How Fukushima is relevant to Kudankulam” in the Hindu (08-03-2012)
The disaster in Japan revealed many risks that were earlier unknown; it is important to assess the risks in India in a transparent manner and explain which are worth taking.
The nuclear plant accident at Fukushima, Japan, in March 2011 exemplifies the prescient remark of nuclear reactor pioneer, the late Alvin Weinberg, that “a nuclear accident somewhere is a nuclear accident everywhere.” After Fukushima, many countries initiated a reconsideration of the role of nuclear power in their current and future energy portfolios and checks of their safety features at operating plants. Public demonstrations for halting ongoing construction of new plants and eliminating nuclear power altogether from energy portfolios also followed. Social demonstrations against the construction of any new nuclear power projects in India and a bringing on stream of the nearly complete Kudankulam plant in Tamil Nadu are parts of this phenomenon.
The Central government's attempts to assure the public of the safety of the Kudankulam plant failed and the demonstrations continued, leading the Tamil Nadu government to appoint an expert panel of four to assess afresh the safety of the plant. The committee submitted its report on February 27, 2012 which is as yet not released. A member of the panel, former Chairman M.R. Srinivasan of the Atomic Energy Commission (AEC), is quoted as saying that the Committee was fully satisfied that the plant was safe.
It remains to be seen whether the report is convincing and credible in coming to its conclusion, thus addressing public concerns about Kudankulam and also possibly blunting the threat to India's future nuclear power programme from escalating demonstrations. Concerns of risks of nuclear power, both from possible design faults in plants, their inappropriate location and from natural events such as earthquakes and tsunami have risen since Fukushima. The committee has to address these concerns effectively in a transparent manner in its report for it to serve its purpose of looking at the issues afresh regardless of the prior public positions of any of its members on them. While awaiting the report, we highlight what the Fukushima accident revealed on the previously unknown or underestimated risks and costs of nuclear power for the reason of their possible relevance for evaluating the risks and benefits of the expansion of nuclear power in India and the operation of Kudankulam.
Issues from Fukushima
The following is common knowledge about the Fukushima accident and its aftermath. First, it was triggered by a very rare natural event — the occurrence together of an earthquake of magnitude 9 on the Richter scale and a 15-metre tsunami which completely overwhelmed the plant and its safety systems. This raises the issue whether the probability of the event could or should have been anticipated or was ignored as unlikely by the Japanese regulatory authorities when the plant was designed, built and located at Fukushima.
Second, the analysts exposed the close ties between public regulators and the private plant operators that could have led them to collude and neglect safety and other features that could have been built into the design of the plant and affected responses to the accident and the timing and transparency of information released.
Third, although the physical structure of the Fukushima plant withstood the earthquake, together with the tsunami, the earthquake led to the loss of offsite and onsite power leaving the plant completely dependent on diesel generators and batteries of emergency cooling system for reactors. But adequate emergency power was not available at Fukushima. The consequential build-up of temperature resulted in production of steam and hydrogen that exploded rupturing the containment structure within a matter of hours and eventually led to a partial core meltdown.
Fourth, radiation leaks from the disabled plant spread far beyond what had been deemed likely, affected rice crops, milk and other products for domestic consumption and exports. The leaks and damages beyond the plant emphasised that containment structures have only a limited time-bound ability to mitigate the consequences of releases of radioactivity into the containment by overheated reactors coolant accidents until emergency cooling systems prevent further heating and a core meltdown. At Fukushima, emergency cooling systems failed and led to a partial core meltdown. Just a few hundred metric tonnes of steam could pose a serious threat to the containment's structural integrity of Kudankulam with its VVER-type reactor. It is therefore essential that cooling systems operate reliably and effectively.
A complete analysis of the Fukushima accident is not available yet. From what is available, it is known that radiation leaks affected crops and population and resulted in loss of output from disruptions in power supply. Kudankulam is located in the rice and milk producing, heavily populated and fast growing southern state of Tamil Nadu near Sri Lanka. The deleterious consequences of the Fukushima accident and the risks of their happening at Kudankulam are real. Obviously potential risks and their costs have to be weighed against potential benefits from the plant in a scientific, social cost/benefit analysis in evaluating whether or not to bring Kudankulam on stream and institutionalising such analyses in the nuclear decision-making process.
Fifth, emerging information on actions not taken but considered at Fukushima is disturbing: “in the darkest moments of the nuclear accident last year, Japanese leaders did not know the actual extent of the damage at the plant and secretly considered the possibility of evacuating Tokyo [350 km away from Fukushima], even as they played down the risks, an independent investigation into a report has disclosed”. (International Herald Tribune, February 29, 2012)
The panel's report should include estimates of the probabilities of earthquakes of magnitude greater than 6 and of tsunamis originating outside India that could threaten the Indian coast. Social cost/benefit analysis of alternative responses to very low probability events, which, were they to occur could inflict large social costs in terms of population loss, damages to structures and long term health consequences is a difficult analytical problem. However, to assure that the Kudankulam plant is “reasonably safe,” the panel should attempt the difficult social cost/benefit analysis and make public its methodology and assumptions. The uncertainties in the data used and in estimation errors induce an “error band” around the average social cost/benefits and these should be made explicit.
Superimposition of estimated probabilities of possible reactor accidents with site specific probabilities of earthquakes and tsunamis highlighted by Fukushima would enable the estimation of probabilities of a Fukushima-like event at Kudankulam.
Regulatory independence
The Fukushima accident highlighted the need for the independence of regulators from plant operators. The Atomic Energy Regulatory Board (AERB) has long been criticised for being subservient to DAE, the promoting organisation for nuclear power. After Fukushima, the establishment of a truly independent regulator has been promised. Currently, institutional deficiencies are structurally inbuilt and hard to eliminate. If they remain, the credibility and autonomy of the regulator cannot be ensured. Historically, nuclear policymaking in India was not transparent and involved only a handful of people in the government. The DAE has exploited this arrangement. Unfortunately, the political leadership left the operational aspects of nuclear affairs entirely to DAE without creating any institutional mechanism for independent technical and policy advice on civilian as well as military aspects.
A glaring example of DAE's misuse of the Atomic Energy Act to escape the scrutiny of regulator and courts over public safety concerns came in the wake of the still unpublished 1996 AERB report. The report is believed to have exposed how DAE had turned regulation into a farce because of the cosy arrangement between the regulators and the regulated. In India, all Indian nuclear plants are in the public sector and so are the agencies that exercise regulatory functions and promotional responsibilities. In this situation, conflict of interest between regulation and promotion is inevitable. Their separation and the creation of a statutory body for regulation are essential to win public confidence.
Energy portfolio
Significant shortfalls of India's energy generation relative to estimated energy demand have been longstanding. Many policy failures contributed to the shortfalls and their consequences. Amongst them, the failure to implement the Electricity Reform Act of 2003 ranks high. Legitimate concerns about global warming and energy security have driven the proposed expansion of nuclear power. As a poor country with a growing population with a need for rapid and sustained economic growth to eradicate poverty, India faces the daunting task of increasing its energy supply by a factor of two to three over the next two decades even after factoring in feasible conservation and efficiency improvements. Every possible source of energy (fossil, renewable, and nuclear) has to be considered without any a priori opposition to the use of any source in any credible social cost/benefit analysis of alternative energy portfolios in meeting development goals without pushing their risks beyond socially tolerable levels.
Understandable public concerns post-Fukushima pose enormous challenges for the planned expansion of nuclear electricity generation in India. Neither technological hubris nor shrill anti-nuclear rhetoric is useful in this context. For this reason the panel has to examine critically what Fukushima revealed that was not known before in terms of risks and social costs of a potential accident over a long term and offer its informed assessment of the extent Kudankulam and other future plants are subject to known and potentially new risks. Its assessment and judgment need to be transparent and explain which risks it considers worth taking and why.
We urge that due consideration be given also to issues that human frailties, potential natural disasters like earthquakes and tsunamis and acts of sabotage pose to the potential failure of well designed but complex engineering systems like a nuclear reactor. No humanly designed system can ensure that it will never fail — thus an option with zero risk does not exist. For this reason, a credible and convincing social cost benefit analysis of risks and benefits of current and available future energy options is essential.
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