Nuclear Threat to Karachi:K2 NPP siting controversy and its solution

Syed Akhtar AliChairman Research on Economy and Politics

of Pakistan(REAP)-0345-2447714,akhtarali1949@gmail.com

I am Pro-Nuclear, Others may differI believe that:• Nuclear Power is Economic• It is an effective solution for our energy

needs(100 Sunar Ki 1 Luhar ki)• Nuclear Weapons have served as useful

deterrent guaranteeing our freedom• Chinese are our time-tested friends. They are

highly developed now. Chinese reactors would be as safe as from anywhere

Proposed location of K2 is unsafe• Recognize that proposed GEN-III NPPs are safer

than the previous GEN-II reactors, but• Nothing is 100 % safe• Accidents ala Fukushima, Chernoble may occur• What happens to Karachi esp the following;• Densely populated Karachi

West(Sadar,Lyari,SITE,Baldia & Orangi)• Economically important areas like Seaport,

I.I.Chundrigar Road, Grain Market

Proposed Site violates …….• Proposed K2 Site is in violation of all

international planning guidelines and norms• It is against principle of uncertainty• It is not prudent• It is infact quite a rash siting decision

approved in indecent haste ,surreptitiously, bypassing due EIA process

• Infact it is out of line with PNRA Rules as well

Main Objection and criterion

• Proposed site lies within the Emergency Evacuation Zone EEZ or UPZ as defined by most international norms.

• The neighborhood area is one of the most densely populated of the world.

Population Density• Karachi-6000 persons per Sq.kms• Karachi West-20,000 persons per sq.kms• Japan : 337• Fukushima :55.5

Population density around Fukushima

Population of nearby communities to KK2

Community PopulationRoad distance-km

St.line distance

Orangi 1,540,200 25 18.75Baldia 406,165 22 16.5Lyari 2,700,000 24 18Saddar 616,051 28 21SITE 467,560 22 16.5Kemari 383,788 22 16.5Total(1998 census) 6,113,764

Estimated current

8,559,270

1)current population should be atleast 40% more than the 1998 Census2)Straightl ine distances have been assumed to be 75% of the road distances.

NPP Emergency planning zones

• On-Site: Internal zone, under control of NPP operator • PAZ: Precautionary Action Zone (5 kms)• UPZ: Urgent Protective action planning Zone(17-25

kms) • LPZ: Long-term Protective Zone (Food Restriction

Planning Zone-FRPZ) -85-300 kms• • .

US NRC Guidelines• Locating reactors away from densely

populated centers is part of the NRC's defense-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.

• Reactor sites should be located away from very densely populated centers. Areas of low population density are, generally, preferred.

USNRC: distance to Population Centres

• The nearest distance to the boundary of a densely populated center containing more than about 25,000 residents must be at least one and one-third times the distance from the reactor to the outer boundary of the LPZ.(10 kms from the outer boundary of LPZ of 25-30 kms)

US NRC rule 3:• A reactor should preferably be located such 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 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.

AERB India code ‘Code of practice on safety in nuclear power plant siting’,

• provides three desirable parameters for ready acceptance of the site.

• 1. Population within sterilised zone (5km radius) : less than 20000

• 2. Distance of population centres (>10000 person) : More than 10km

• 3. Distance of large population centers (>100000 person) : More than 30 km

Para 5.2.i of SRO 911(I) PNRA,• concerned with Nuclear Siting, requires impact evaluation

under accident condition, although it does not specify the severity on INES scale, a flaw that one would like to be rectified in the light of similar rules in other countries. “For each proposed site, the potential radiological impacts in operational states and in accident conditions on people in the region, including impacts that could lead to emergency measures, shall be evaluated with due consideration of the relevant factors, including population distribution, dietary habits, use of land and water, and the radiological impacts of any other releases of radioactive material in the region.”

PNRA Guidelines • PNRA’s gazette guidelines provide for special

considerations for large cities. part of para 6;• A population center distance of at least one and one-

third times the distance from the installation to the outer boundary of the low population zone. For this purpose, the boundary of the population center shall be determined upon consideration of population distribution. Political boundaries are not controlling in the application of this requirement. Where very large cities are involved, a greater distance may be necessary because of total integrated population dose consideration

No hindrance to Ingress and Egress(IAEA Safety Guide)

• Before final approval of a nuclear power plant site, the feasibility of an emergency plan should be demonstrated. There should be no adverse site conditions which could hinder the sheltering or evacuation of the population in the region or the ingress or egress of external services needed to deal with an emergency.

Proximity to a City-hindrance to Evacuation(IAEA Safety Guide)

• 6.4. The presence of large populations in the region or the proximity of a city to the nuclear power plant site may diminish the effectiveness and viability of an emergency plan. 6.6. If, upon evaluating the aforementioned factors and their possible consequences, it is determined that no viable emergency plan can be established, then the proposed site should be considered unacceptable.”

Comparative populations and Population DensityUSA India Fukushima Sanmen PAEC-K2

Maximum Population Density 300* 20000Minimum Distance-kms 30kms **

Population Density-20 kms 68.8 20000Population density-30kms 55.5 20000

Population-20 kms 86300 800000

Population-30 kms 156800200000

0US MPD@20 miles**from a population centre of 100,000 *

Table___: Comparative zoning distances in countries

PAEC USA Fukushima Europe-JRC India

Evacuation Zone(kms) 10 17 30 25 16Ingestion Zone

Contamination Zone 85 85 300

Lack of Due Process• Convention on Nuclear Safety and IAEA NPP

Siting Guidelines require open and transparent NPP Siting Process and decision-making.

• Pakistan’s National Reports to CNS reaffirm to that requirement

Has PAEC considered possibility of nuclear accident at all ?

• PAEC claim of very low level radiological impact of 0.02 mSV as opposed to EIA results elsewhere(10-100 mSV)

• False value• Incomplete statement(normal operation)• Hiding inconvenient details• Nuclear accident has not been considered.

US NRC: ref exposure level

• 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," requires that at any point on the exclusion area boundary and on the outer boundary of the LPZ the exposure of an individual to a postulated release of fission products (as a consequence of an accident) be less than 25 rem(250 mSV- a person dies @1000 mSV) total effective dose equivalent, for specified time periods.

Exceptions donot prove the rules• NewYork Indian Point Reactor;26 kms away;

much less population density ;strong public demand to close it down

• Netherlands: very small geographical area• EU New Guideline has increased its Hazrdous

area to 30 kms from a previous lower level of 20kms.

Union Carbide Tragedy-Encroaching Population

• Others estimate 8,000 died within two weeks and another 8,000 or more have since died from gas-related diseases. A government affidavit in 2006 stated the leak caused 558,125 injuries including 38,478 temporary partial injuries and approximately 3,900 severely and permanently disabling injuries.

• Initial

KeMari Town_required for expansion and not for restriction

• Population around Union Carbide Plant was very small, it grew later. Can the proponent guarantee that the population around its site will not grow. Can it buy-out the whole Kemari Town Land? Would it be possible? Or adviseable.

• In fact, we look forward to the closing down of Kannup, at its designed life. No extension is awarded to it any more.

Recommendation• Affected Population is whole Karachi West

including vital socio-economic Centres of I.I.Chundrigar Road , Seaport and Food Grain market, and not a few Goths as claimed by PAEC

• Proposed location endangers Karachi generally, and Karachi-West in particular

• Go towards Gadani@ 50 miles• Adopt USNRC distance standards of 16-50 Miles• Shun Secrecy: Organise a full scope EIA with

public oversight and participation