December 30, 2011
The Expert Team
The People’s Movement Against Nuclear Energy
Idinthakarai 627 104
The Honorable Chief Minister
Government of Tamil Nadu
Chennai 600 009
Greetings! We, the Expert Team of the People’s Movement Against Nuclear Energy (PMANE) has met today at Kanyakurmari and confirms the worst fears of the people that the Nuclear Power Corporation of India (NPCIL) has compromised on safety and failed to perform statutory due diligence. Citing the responses on the matter of siting and the issue of fresh water supply – both critical components in determining safety of the plant – we confirm that NPCIL has compromised on both these aspects.
May we bring your kind attention to the following issues please:
1. The Koodankulam site is not only prone to small-volume volcanic eruptions, but also to mega-tsunamis with heights exceeding 100 feet, arising out of the presence of two large “slumps” in the seabed of Gulf of Mannar less than 100 km from the plant. A 1982 study in a noted journal documents the presence of two slumps — the East Comorin slump and the Colombo slump — in the vicinity of the Koodankulam site. The second report by the Central Govt Expert Group has accepted the presence of the slumps and the possibility of a Near Field Tsunami occurring out of a landslide. This is in opposition to their earlier position and also to the position of AERB that Near field Tsunamis are not possible in India. However, their contention is on the height of the Tsunami waves. While welcoming their change in accepting the possibility of Near Field Tsunami, the PMANE Expert Team wishes to state that after the 1982 study, a tsunami did occur in December 2006 and it may have changed the structures of the Slumps. Hence merely answering the question from the 1982 text is not sufficient.
2. PMANE’s Expert Team is alarmed that NPCIL has allowed the siting of the plant in an area characterised by sub-volcanic intrusions – an indication of volcanism in the vicinity of the plant. The presence of sub-volcanic intrusions of the kind found in the KKNPP site is precisely the reason why the United States Government abandoned the Yucca Mountain site as a possible waste storage site owing to concerns about the structural integrity. In addition to this, small volume volcanic eruptions have occurred in the KKNPP site’s vicinity from the year 1998.
3. Studies by ONGC, the Geological Survey of India and numerous other terrestrial and marine geologists confirm the presence of basaltic intrusions into the crust and the Gulf of Mannar seabed. Their findings tell us that the Gulf of Mannar sea bed has been thinned because of this. Its thickness is a mere 1,000 to 5,000 metres instead of average 40,000 metres for continental crust.
4. Scientists from various national institutes have published as late as 2010 that the crustal thickness of Koodankulam site is much thinner than the Gulf of Mannar Crust because of similar sub-volcanic intrusions. Ground Magnetic Surveys conducted by them have suggested that the Crustal thickness is a mere 150 to 200 metres at Koodankulam site.
5. The entire Koodankulam region is known for its lime stone formations. Lime stone formations are known to the formation of Sink holes and underground caves. Events that occurred on November 26, 2011 at Pannaiyarkulam, in 2008 at Radhapuram (both located 10 kms from the KKNPP site), and in 1998 at Maruthankulam (25kms from the KKNPP site) have suggested that this is a “KARST” Region. AERB’s safety laws clearly state that if a Karst region is suspected a detailed study has to be conducted. Such a study has not been attempted by the NPCIL.
6. During the 2004 tsunami the withdrawal of the sea was around 4-5 Kms from the shore. Every year after this tsunami, the some places of the coast of Tamil Nadu have faced the issue of sea water withdrawal at least 3 times a year. Tsunami hazard manual released by the USNRC in March 2009 states that if sea water withdrawal is an issue at the site then the chances of the reactor going in for a dry intake should be studied thoroughly. Dry intake can cause damage to the turbines and reactors. Each minute a reactor needs 5,000 cubic-metres of sea water. Hence a detailed volcanic hazard study, tsunami hazard study and a study about the “Karst” Terrain is a must.
7. Another crucial failure of the NPCIL is the fact that the plant has been assured supply of freshwater for merely 36 hours and 25 minutes. The dependence on a single source, namely, the desalination plants, further reduces the reliability of this water source because desalination plants rely on the sea and electricity. Both can be disrupted by disturbances in electricity supply and cyclones and extreme weather events in the sea along with Jelly fish intrusions. In such a situation, reactors will have to be closed down immediately and they may have just enough water for maintaining the safety systems for only 10 days. The reserve of potable water for the KKNPP Township is sufficient only for 2 days. The seawater intake pipeline of the Minjur desalination plant in Thiruvallur district was uprooted during the Cyclone Nisha in 2008. Repairing the pipeline required engineers from the Netherlands and it took more than 45 days to mend the pipeline.
8. Department of Atomic energy (DAE) funded study by Dr. Manjula Datta has found that the morbidity burden in the proximity villages of Kalpakkam is 400% higher than in distant villages. The diseases include Cancer, mental retardation, thyroid problems, infertility, lumps, stroke, cataract, TB, ulcer and diabetes. Another study conducted by Dr. V. Pugazhendhi et. al. showed that auto immune thyroid disease among women living in upto 40 kms from the Kalpakkam site was significantly higher than those living 500 kms away. In another study conducted by the same doctor in 2003 among the Kalpakkam employees and family members had shown that the death rate due to Multiple Myloma (a bone marrow cancer) is statistically significant. Studies based on data supplied by the NPCIL shows that the prevalence of cancer among workers and wives of the BARC and the TAPS is significantly higher than that found in MAPS. The first 2 reactors became critical during the 1960’s and the 1970’s whereas the MAPS came critical during 1984-85. Yet another study shows significant deviation in sex-ratio of children born to employees of the BARC and the TAPS which is indicative of genetic mutations.
9. The United States and Japan have compensatory laws for employees as well as people living around the plants (such as energy employees’ occupational illness compensation program act) even when the reactors function normally without any leaks or accidents. This clearly shows that Low level Radiation from the reactors is a health hazard.
10. The airports in European Union have banned the usage of X-rays due to the hazards of low level radiation and there is no safe dose in radiation.
11. The decommissioning cost of the KKNPP reactors must be taken into account and that cost is at least a few times higher than the commissioning cost. In Fukushima it has been estimated that it will cost 75,000 crores and 30 years to decommission the failed nuclear plants. When we take this into account, all the nuclear plants become unviable and un-economical.
12. The issue of spent-fuel disposal is an unsolved issue both in terms of technology and economics and spent-fuel will remain highly radioactive for thousands of years.
13. Only enhancing energy efficiency and developing alternatives will give a sustainable energy solution. Effective energy efficiency measures alone can free up enough electricity to meet all our current needs.
Given this situation, we would like to request Your Excellency to bring up the above issues with the Central Government and the Department of Atomic Energy and persist with your concern for the wellbeing of the people of Tamil Nadu. We would like to request you to accelerate electricity generation from renewable energy sources such as the solar, wind and bio-mass which are available in plenty in Tamil Nadu. We would also like to request you to implement appropriate policies and action for grid connected renewable energy generation and distribution. Tamil Nadu has got great potential for solar energy (25-30 MW per sq. Km.) as we have 300 cloud-free days in a year. We can surely establish Tamil Nadu as a pioneer in renewable energy in India and such a fete can coincide nicely with the “International Year of Sustainable Energy for All.”
We would very much like to request Your Excellency to grant us an opportunity to meet with you and explain our reservations to the implementation of the KKNPP project in detail.
1. Mr. M. G. Devasahayam, I.A.S., Convener of PMANE Expert Team
2. Dr. R. S. Lal Mohan,
3. Dr. V.T.Padmanabhan
4. Dr. R. Ramesh
5. Dr. V. Pugazhendi
6. Mr. Soumiya Dutta
7. Adv. T. Lajapathi Rai
8. Prof. P. Sivakumar
9. Mr. G. Sundarrajan, Coordinator of PMANE Expert Team