1) The NPPs would be supplied by Chinese who are not as competent as the traditional suppliers from the US, France and Russia. The technology is new and not tried and tested. China has acquired this technology from the US recently and has cannibalised it which can be risky from a safety point of view. And that China is using Pakistan as a guinea- pig to try out these plants.
2) The NPPs are expensive and the nuclear power coming out of this project would be costly and unaffordable.
3) It is highly unsafe to site the plants in the vicinity of KANUPP, as any reactor accident a la Three-Mile Island or more recently Fukushima etc may cause irreparable damage to life and property of a major city of the country.
While I do not agree with the first points, and may only partly agree with the second but agree fervently with the third. Let us take the issues one by one. Before I do that, I may clarify that I am a supporter of both civilian and military (nuclear weapons) technology. I believe that nuclear weapons have done tremendous contribution towards our national security by bringing about a détente and counter capability. For a smaller country facing a much larger adversary, nuclear weapons have been a good deal. Thus what I am submitting may not be dubbed away as coming out of traditional opponents of nuclearization and nuclear energy.
Are Chinese nuclear reactors safe?
ACP-1000 reactor that is being supplied by China is of Westinghouse origin (adapted from AP1000). It is a third-generation reactor based on tried and tested PWR design. Some people have confusion about it who term it altogether a new design requiring extensive testing. This is the safest design ever developed in the world. Westinghouse PWR designs have been implemented in more than 50% of the current nuclear power installation of the whole world. Nuclear Regulatory Commission (NRC) of the US has given its type approval after many years of the approval process. Several such reactors are being installed in the US itself. China is in the process of installing several such reactors. China plans to install 30 such reactors by 2030.It has bought Westinghouse technology and designs, which fact is being soft-pedalled to avoid criticism from NPT lobby.
AP-1000, among other innovations, has passive safety features like shutdown during critical faults and emergencies under a natural forces regime of gravity and air pressure without necessarily requiring communication and power which may itself be out of order due to the fault. For example, Water Tanks on the top of reactor buildings have been provided to supply water during emergency shutdowns. It would flow with as much ease as we use overhead storage tanks in our houses in Pakistan. There is double containment vessel to block radiation leaks. Outer containment vessel is crash proof against aero planes intentionally or unintentionally ramming into it. Seismic designs have been rationalised at 0.3g seismic scale. These kind of safety features were being longed for a long time. And now it has come to the market. A design is not to be rejected because it is new. The choice is between adopting the latest technology which is much safer or the earlier technologies of 1970s vintage which are decidedly much less safe. To the extent Chinese are willing to supply and finance, nuclear power can be installed and sustained. NPT issues would keep all the Western Countries out of this business with Pakistan.
THE SITING CONTROVERSY PAEC the project proponent has launched its own public campaign and recently held a seminar in a local hotel in Karachi last week in which responsible PAEC and PNRA (Pakistan Nuclear Regulatory Authority charged with the task of regulating nuclear energy) including chairman participated. A brief was circulated defending their position on siting two 1100 MW nuclear power plants called K2 and K3 at or around the existing KANUPP site at Paradise Point.
PAEC maintains that the site chosen is the best among the available options and puts forth the following arguments and reasons justifying their claim;
1. Sites at greater distances along the coast are vulnerable to a higher seismic risk because of their proximity to seismic fault lines; or they do not have an appropriate height above Mean Sea Level; or there are greater flood risks. The rock type under the surface and the absence of groundwater are also important considerations for selection of the present site. A plant built at any place along the coast other than at this site would have been prone to risk from earthquakes and tsunamis, and plant vulnerability would also have been higher because of poor soil conditions. Also an adequate seismic design factor of safety has been taken (g=0.3).
2. KANUPP already has a well defined emergency plan drawn up according to regulatory requirements, duly approved by PNRA, and adopted by the local authorities. This plan caters to the evacuation zone of up to 5 km which is the requirement for KANUPP, and exercises are regularly carried out to test and improve the implementation of these plans. Similar plans will also be a part of the documentation for the new reactors....even the current US regulations do not require the plant emergency programs to plan any evacuation beyond 10 miles.
Whoever has read the PAEC brief is not convinced of the siting decision. Karachi is a city of more than 25 Million or so now. Siting a nuclear power plant so close to it at Paradise Point, is definitely going to cause fear and controversy. As we will demonstrate in this space from the evidence in many countries, that in almost all the countries effort is made to locate nuclear power plants quite away from the population centers, and in particular the large cities. Even PNRA's gazette siting guidelines require additional considerations for large cities. It is not sufficient to argue that KANUPP has operated for the last 40 years without any catastrophe thus more of the same can be done without any compunction or reservation.
One would take this reasoning with a pinch of salt. There is no safe and suitable site other than the proposed one where to site a nuclear power plant. This is a counter-productive argument strengthening the thesis that Pakistan being an earthquake and Tsunami (not the political tsunami) prone country, nuclear power plants are too dangerous to be located here. Mere statements on unsigned plain papers may not be enough to prove their point of view and getting it accepted. There is a structured EIA process wherein site choices are examined and site ranking done and mitigation plans developed under public scrutiny and oversight. What national security is endangered in such a site ranking made public?
However, he proponent has chosen to get SEPA's approval in a secret manner bypassing the standard process scrutiny. The national committee of IUCN, a credible environmental body operating in the country has demanded a full-scope and open EIA. The project, in my view, would have got more credibility and acceptance, had you chosen to make public certain safety related details, proactively. Belated explanations are coming after some individuals have publicly aired their point of view. IAEA's siting guidelines provide for the due process and public participation. It is a part of our civilian nuclear programme, where National Strategic considerations and secrets are not involved. It is highly advisable that the two programmes are kept separate. IAEA safeguards would ensure that such is the case. Against this background, pursuit of secretive processes and bypassing standard procedures is not understandable. All democratic societies involve open and inclusive approaches involving public participation in nuclear siting decisions. Even in India, full-scope EIA is done with public participation. AERB (Atomic Energy Regulatory Board of India) has also started sharing safety data, studies and determinations with the public.
There are, among other economic and operational criteria, the following three major considerations in siting a nuclear power plant:
1. During normal reactor operations, nearby populations should be safe from radiological and other emissions and effluents
2) Minimum risk of damage to human life and health in case of a nuclear accident or emergency whether designed for or beyond design.
3) Minimum risk to economic and social life of inhabitants in the area
On all these considerations, the proposed site fails to earn a good rating despite claims made to the contrary by the relevant quarters. We will advance our argument and bring evidence to support our differences. However, some nitty-gritty of detail is important at this stage.
To implement these broad principles, in addition to the relevant studies and evaluations, following two siting parameters have been provided for by the international and national nuclear regulatory authorities:
1. An Emergency evacuation zone of (16 kms around the nuclear power reactors)) has been defined which mandates compulsory evacuation in that zone, should there be some nuclear accident involving leakage of radioactivity at an unacceptable scale. Many people argue that this range is not enough. We have seen that evacuation in case of Fukushima was from much larger zone. The US government advised its nationals to evacuate out to a 50 Miles distance.
2. A contamination zone of 50 Miles has been defined where there may be risk to food and water contamination. Extensive monitoring of food and water sources is mandated in this zone in case of a nuclear accident involving radioactivity leakage and release.
Unfortunately, PAEC is focusing its considerations on this narrowly-defined 16 kms region and is seemingly oblivious of food and water contamination possibilities and the risk of disorder in a city like Karachi which is normally unmanageable and suffers from routine anarchy and not to talk of terrorism. And even in that narrow consideration, it is underestimating the magnitude of the problem in evacuation of risky populations.
In the case of Paradise Point (KK-2), it may be noted that it is situated in the densest part of Karachi called Karachi West; the adjoining communities of Orangi, Lyari, Baldia, SITE area etc have a combined population of 8.55 million people living within 20 kms. Also Clifton and Defence and PECHS are also within more or less 20 kms. It must also be noted that in these advanced and affluent countries, it is a lot easier task to evacuate. Most people have cars and money to eat and survive for days if not weeks on their own. The disaster management data from Japan, for example, tells us that only a few persons have to be assisted in most emergencies. People leave on their own unassisted. In our case, neither the people nor the government have money and resources and nor are we organised adequately. I have personal experience of evacuation during the oil-spill tragedy of Karachi and know how difficult and painful it can be. Moreover, the food and water gets contaminated in a radius of 50 Miles which means, all Karachi including Port Qasim Area would have potential for food and water contamination, in case of a nuclear accident or emergency.
As to the KANUPP's regional spatial control in the area, residents of Karachi know that all kinds of activities have been allowed in the vicinity of KANUPP. Hawkesbay Scheme-42 has been floated and allotments have been made. Within a few years, lacs of people are going to be populated there.
PAEC's explanations are not presenting or defending its emergency evacuation plans but are decrying the need of doing so. They argue that emergency evacuations may cause more problems and deaths than otherwise. How can a population of 8 million people be evacuated within 72 hours (the emergency cooling duration capacity of the reactor) of accident? The only exit points are Banaras Chowk, Kharadar, Gulbai which cannot even cope with normal traffic. It is obvious that they do not have a viable evacuation plans or even elements of it. While IAEA guidelines mandate evacuation plans. If the feasibility of an evacuation plan for a site cannot be demonstrated, IAEA guidelines require that such sites may not be selected.
Universal siting norm
As a general Siting Rule, almost universally, Nuclear Reactor siting away-from-population centers is a norm and makes common sense. Let me reproduce, the excerpts from NRC (USA) Guidelines on the subject;
As stated in 10 CFR 100.21(h), "Reactor sites should be located away from very densely populated centers. Areas of low population density are, generally, preferred.... Locating reactors away from densely populated centers is part of the NRC's defence-in-depth philosophy and facilitates emergency planning and preparedness as well as reducing potential doses and property damage in the event of a severe accident. Numerical values in this guide are generally consistent with past NRC practice and reflect consideration of severe accidents, as well as the demographic and geographic conditions characteristic of the United States.
Preferably a reactor would be located so that, at the time of initial site approval and within about 5 years thereafter, the population density, including weighted transient population, averaged over any radial distance out to 20 miles (cumulative population at a distance divided by the circular area at that distance), does not exceed 500 persons per square mile. A reactor should not be located at a site whose population density is well in excess of the above value.
There are 100 nuclear power reactors in the US with a total installed capacity of slightly more than 100,000MW. In the enclosed Table, we have provided population data for 13 most dangerously located reactors. Out of these, only 4 nuclear reactors namely Indian Point (NY), TM Islands (Penn), Limerick (Penn) and McGuire (NC) have a populations of 880,820 to 1,187,284 living within 20 miles of the nuclear reactors. In most other locations, this number is typically under 200,000. Even in this list of dangerous locations, one would find sparse populations in quite a number of situations. In the category of 10 miles (17 kms) distance, even Indian Point (NY) would fare better than our proposed KK-2; a population of 272,539 as opposed to more than a million living within 17 kms of KK-2.Typically, less than 50,000 people live within 17 kms of nuclear reactors in the US as can be seen readily from the table. The figures match even with China where environment and safety issues may fare lesser on agenda, as is the common belief. We have provided numbers on China as well in a table. PAEC has selected only the worst possible example to prove its case. (May be God has chosen New York for potential catastrophes for its sins).
NPP siting framework in India: A full scope EIA with public participation is provided in Indian law. Apart from AERB (Atomic Energy Regulatory Board), there is jurisdiction of local and regional bodies and EPAs. EIA and AERB guidelines provide for the following distances and rejection criteria of potential sites. One may note that no population centers of more than 100,000 are to be there within 30kms of the NPP.
Chinese NPP location framework: We would reproduce here from a highly credible Chinese source (reference provided in the end):
Nuclear power plants should be built in those areas where the population density is relatively low and the district average population density is relatively small. Nuclear power plants shall keep a proper distance from towns and cities with populations over 100,000 inhabitants.
Malaysian framework: Malay-sian Guidelines provide for rejecting a potential site if the distance to a population center of 25000 persons or of population density of 250 persons per sq kms is less than or equal to 10 kms.
(To be continued) The views expressed and conclusion drawn are not necessarily those of the newspaper
Population of nearby communities to KK2
Community Population Road St. line
Orangi 1,540,200 25 18.75
Baldia 406,165 22 16.5
Lyari 2,700,000 24 18
Saddar 616,051 28 21
SITE 467,560 22 16.5
Kemari 383,788 22 16.5
Total (1998 census) 6,113,764
Estimated current 8,559,270
1) current population should be at least 40% more than the 1998 Census
2) Straight line distances have been assumed to be 75% of the road distances.
13 most dangerous nuclear reactor locations in the US
Reactor Name State 10 miles (1) 20 miles (2)
Seabrook New Hampshire 118747 464872
Vermont Yankee Vermont 35284 147109
Pilgrim Massachusetts 75835 307359
Millstone Connecticut 123482 317466
Indian Point New York 272539 1187284
Oyster Creek Philadelphia 133609 485719
Limerick Pennsylvania 252196 1168871
TM Island Pennsylvania 211261 880821
Salem New Jersey 52091 545820
Calvert Cliffs Maryland 48798 181324
Saint Lucie Florida 266595 420273
McGuire North Carolina 199869 1013135
Source: NBC http://www.nbcnews.com
(1) population living within 10 miles of nuclear reactor
(2) population living within 20 milesa