Site Evaluation Report – Analysis

KUDANKULAM ANTI-NUCLEAR SATYAGRAHA, INDIA, 28 May 2012

People’s Movement Against Nuclear Energy – TRANSCEND Media Service

PRESS RELEASE – May 24, 2012

[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the so called SER mentions the Soviet Union in several places and it proves that the report is also quite old and outdated.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 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)
Idinthakarai & P. O. 627 104
Tirunelveli District, Tamil Nadu
India
koodankulam@yahoo.com

This article originally appeared on Transcend Media Service (TMS) on 28 May 2012.

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