March 01, 2010
Mr. Jairam Ramesh
Hon. Minister
Ministry of Environment and Forestry
Government of India
New Delhi
Re: Jaitapur Nuclear Power Plant, other Thermal Power Plants in Konkan, Maharashtra and the Role of Ministry of Environment and Forestry, Government of India
Dear Sir,
You are aware of the decision of Government of India to a take quantum jump in Nuclear Power generation from the current 4,120 MWe to 63,000 MWe by 2032. The public opinion in the developed countries is against the nuclear power because it is costly and hazardousand the world is trying to move away from it. This decision of our government is nothing but an invitation to disaster.
As a part of this decision, giant nuclear power plant (1650 MWe X 6 units) with a total capacity of 10,000 MWe is proposed to be set up at Madban (Tal. Rajapur; Dist. Ratnagiri) as Jaitapur Nuclear Power Plant (JNPP). The State Government has gone ahead with the forcible land acquisition of 938 ha overlooking the resolutions passed by the Panchayat Committees as well as Zilla Parishad. The local people are opposed to having nuclear power plant in the region. They have been democratically protesting against government actions. Instead of listening to the people’s voice, the state government is unleashing brutal police actions terrorizing people.
Environmental Clearance: The environmental impact report for this project is yet to be finalized. The public hearing is not yet done and concluded. In absence of these, the environmental clearance from your Ministry is further away. However, land acquisition process has been pushed through under the archaic Land Acquisition Act, taking MoEF clearance for the project granted. This undermines the importance and crucial and vital role of Ministry of Environment and Forestry.
Inappropriate Site Selection: It is also known that seismic zone is a very vital criterion in selection of a site for nuclear power plants. The norm as per Vengurlekar Committee recommendations is that nuclear power plant shall not be put up in an area which falls beyond seismic zone 1 or 2. The site selected for JNPP comes under seismic zone 4. The tremors experienced over the years in Koyna valley and Ratnagiri district makes the site inappropriate for a nuclear power plant. The recent tremors from end September ’09 to end December ‘09 experienced in this region have created a crater; 40 ft long & 40 ft deep on a state highway and changed the course of a rivulet, just a few kilometers away from the site selected for JNPP (India TV Prime Time, Special Report dated Feb. 2, 2010, 9:30PM). Pushing a nuclear project ahead at such a site would mean that India will be sitting on hundreds of Chernobyl or many TNTs of atom bombs.
Cost, Safety and GHG Emissions: It is an established fact that nuclear power generation is very costly; even on paper, for imported plants, it is at least two times the cost of generation of electricity from coal and gas, and taking into account all the hidden subsidies, actually much more.
Areva, the French company, with whom NPCIL is talking to for supply of nuclear reactors for JNPP, is setting up first such reactor at Olkiluoto in Finland. The project, started in 2005, was originally scheduled to complete in 2009 but due to detection of numerous flaws it is delayed and is unlikely to be finished by 2012. The cost of project has already almost doubled up from Euro 3.0 billion to Euro 5.5 billion i.e. Rs. 12 Cr per megawatt capacity to around Rs. 22 Cr. Per megawatt (Fact sheet: Olkiluoto 3, Nov. 2009, Greenpeace Report)while for gas-based plants it is Rs. 4.0 crore per megawatt.
More importantly, nuclear power is extremely hazardous, due to the enormous amount of radiation routinely released into the atmosphere at every stage of the nuclear fuel cycle. An even more monstrous problem is that of safe storage of nuclear waste. No solutions have been found till date. The decommissioning of nuclear power plant is a long drawn and expensive process that can run in to as long as 150 years. These costs are not considered at all. (Caldicott, Helen, Nuclear Power is not the Answer to Global Warming or anything else, 2004)(Half Life: Radioactive Waste in India, Toxics Link, 2009)
The history of various incidences of radioactive leakages, exposure across the world apart from the major accidents e.g. Three Mile Island, Chernobyl, are enough to prove against the claims of safety of the nuclear power plants. The story back home is not any different if not worse. (Safety First? Kaiga and Other Nuclear Stories; M. V. Ramana, Ashwin Kumar, Economic & Political Weekly, Feb 13, 2010, VOL XLV No 7)
Finally, considering the complexity of the technology of a nuclear reactor, there is no way to guarantee that a serious accident at a nuclear power plant will not take place. An accident at a nuclear power plant is not a simple accident; it affects the very sustainability of life on Planet Earth. (Elliot David, Ed., Nuclear or Not, Does Nuclear Power Have a Place in a Sustainable Energy Future? 2007)
Nuclear energy is also no less harmful in greenhouse gas emissions as compared to coal or gas fired electricity generation. To appreciate this fact one has to consider manufacturing of massive quantities of steel, concrete etc for the plant and the entire nuclear cycle – cradle to grave – from uranium mining to waste storage.
Other Risks associated with Nuclear Power and Environment: Fission of atom results in radioactive elements. Radiations cannot be seen, felt or tasted. When exposure to radioactivity is low, the effects are also not seen immediately. The steam, gases and water released from nuclear power reactor can lead to radioactive contamination of the surrounding affecting trees, livestock, fish and people. Exposure to radioactivity leads to increase in incidence of tumors, cancer, infertility, congenital deformities, stillbirths etc. The most serious matter is that due to genetic mutations these can be transmitted through generations. (Wasserman Harvey & Soloman Norman, Killing Our Own: The Disaster of America’s Experience with Atomic Radiation, 1982)
Lacs of litres of sea water sucked in and released into sea at a higher than the ambient temperature everyday will severely damage marine life. Fish & fishing will be in danger. The increased temperatures of the surroundings, billowing clouds of steam, will endanger and over a period destroy the well developed mango, cashew, other horticultural crops, forests and also health of people.
Imported Reactors: NPCIL is in the process of getting into agreement with M/s. Areva of France for the supply two new generation 1650 MWe EPR reactors for Jaitapur nuclear plant in the first phase and enriched uranium. These are “European Pressurized Reactors”. This technology is not installed anywhere yet. Hence there is no experience about its satisfactory operation and reliability of safety systems. It is understood that the U.S. nuclear regulatory body has not approved this design yet.
Areva is setting up first such reactor at Olkiluoto in Finland. The experience there is an eye opener. The nuclear regulatory authority of Finland has observed numerous serious flaws in the design and construction of the reactor e.g. flaws in electronics of safety control system, flaws in concrete foundation, welding etc.
The Government of India, the State Government must instruct NPCIL to make their evaluation on all such safety technical aspects and what concrete steps have been taken to avoid such flaws and make it public for scrutiny by third party experts before any decision is taken.
On top of all these matters, the government is proposing to introduce “Civil Liability for Nuclear Damages Bill” in the upcoming Parliament session. This amounts to yet another way of giving state subsidy to nuclear power programme, of course under cover. The bill is said to be designed to shield foreign-reactor builders from the responsibility of the financial consequences of severe accidents. It will shift the primary burden for accident liability from the foreign builders to the Indian operator, in other words, the state. (Ignoring lessons of Bhopal and Chernobyl, Brahma Chellaney, The Hindu, 16.2.10)
Considering all the factors above, it is quite evident that nuclear power is not the solution to our problems of power shortage.
Thermal Power Plants and Mining Projects: Apart from the Nuclear, there are 8 coal-based thermal power plants of 23,000 MWe capacity proposed in Raigad, Ratnagiri and Sindhudurg districts of Konkan. The State Government has also accorded permissions to mining projects in Mandangad, Dapoli and Dodamarg talukas. Huge piles of stored coal and fly ash will contaminate water bodies in the surroundings. The pollutants e.g. sulphur dioxide, nitrogen oxide, carbon monoxide and carbon dioxide along with arsenic, cadmium will spread over 25~30 km around each plant and contaminate air, soil, water. These proposed projects will result in destruction of ecology and means of livelihood of toiling masses of Konkan. CRZ norms are being blatantly violated. All the eight coal-based power plants and the nuclear power plant to be located along the Konkan coast are based on imported machinery and huge amount of imported fuel, coal and enriched uranium. This will involve heavy traffic by sea resulting in destruction of the mangroves, breeding areas of fish and other marine wealth.
We wish to bring to your notice that each proposed project is separately getting environmental clearances from your Ministry of Environment and Forestry. We are surprised to note that such a large number of thermal and nuclear power plants, mining projects are receiving environmental clearances in a small eco-sensitive strip of Konkan.
What will be the overall impact on the environment of all these projects put together? We bring to your attention that your Ministry has not even thought and initiated the “Cumulative Environmental Impact” study for Konkan belt.
Energy Security: The contention that the energy needs of future cannot be met without Nuclear Power is erroneous. Energy security can be achieved by deploying strict time bound programmes:- 1) To improve efficiency of generation, to reduce T&D losses and to stop theft; 2) To improve collections of bills for supplied power; 3) To encourage schemes for power factor improvements using capacitor banks, usage of energy efficient lighting, drive motors, machinery in the industry and household gadgets; 4) To curb extravagant, wasteful usage of power by imposing heavy tariffs on large consumers e.g. malls, multiplexes and commercial users of power; and 5) To deploy substantial funds to undertake concrete power capacity addition programmes using renewable sources; especially Solar for small scale dispersed generation and Solar Thermal Hybrid for large scale generation. (Scheer Hermann, A Solar Manifesto, 2001)
The coastal Konkan – a narrow strip – 50 to 90 km wide is ecologically very sensitive and rich in biodiversity: marine, forest, flora and fauna and horticultural crops like the unique, world famous Alphonso mango. The Western Ghats flanking Konkan strip are declared as “Biodiversity Hotspot”. These green districts must be conserved as ‘green’. It is possible to develop the rich natural resources of the region on a sustainable and conservational basis. The special soil and climatic conditions of Konkan are ideal for the production of horticultural, medicinal and aromatic plants, spices, bamboo and other forest plants. Development of small-scale local level processing units and eco-tourism (not the vulgar five star one) can generate eco-friendly employment in the region.
We look up to the MoEF under your leadership to recognize the unique importance of this region and declare it as Green zone, that is not to be disturbed now or in future for the short run private profits in the name of development. Strict enforcement of CRZ regulations would be of considerable help in conserving this rich eco-sensitive region. It is also necessary to stipulate that no coal based power plants, nuclear power plants, chemical and metallurgical industries, mining for export, would be permitted in this region.
We are placing these facts before you for your serious and sincere considerations. We earnestly request your personal and critical intervention in these issues to ensure that script of destruction is not written under the garb of development. We request your acknowledgement and look forward to your response expecting positive actions in the interest of people and the environment.
Dr. G. G. Parikh Dr. Sulabha Brahme Dr. B. J. Waghdhare Madhu Mohite
Arun Velaskar Adwait Pednekar Adv. Girish Raut
Encl.:
- Fact sheet: Olkiluoto 3, Nov. 2009, Greenpeace Report
- Safety First? Kaiga and Other Nuclear Stories; M. V. Ramana, Ashwin Kumar, Economic & Political Weekly, Feb 13, 2010, VOL XLV No 7
- Ignoring lessons of Bhopal and Chernobyl, Brahma Chellaney, The Hindu, 16.2.10